EFTA00127205.pdf

1 2 3 4 DIGITALLY RECORDED 5 SWORN STATEMENT 6 OF 7 8 9 OIG CASE #: 10 2019-010614 11 12 13 14 15 16 17 18 DEPARTMENT OF JUSTICE 19 OFFICE OF THE INSPECTOR GENERAL 20 DECEMBER 2, 2021 21 22 23 24 25 RESOLUTE DOCUMENTATION SERVICES 28632 Roadside Drive, Suite 285 Agoura Hills, CA 91301 Phone: EFTA00127205 LIMITED OFFICIAL USE 1 APPEARANCES: 2 3 OFFICE OF THE INSPECTOR GENERAL 4 BY: 5 BY: 6 7 8 WITNESS: 9 10 11 12 OTHER APPEARANCES: 13 NONE 14 15 16 17 18 19 20 21 22 23 24 25 EFTA00127206 LIMITED OFFICIAL USE 3 1 MR. : All right. The recorder 2 is on. There is also going to be - I'm just 3 going to go over, like, a list of - it's kind 4 of, like, an introduction, and just kind of a 5 preamble into what we are going to be 6 discussing, and who you are. It's going to 7 sound very scripted, and that's because it 8 pretty much is. But you are there still. 9 Correct? 10 MS. : Yes. Mm-hmm. 11 MR. : Perfect. All right. So, 12 my name is and I am a Senior 13 Special Agent with the U.S. Department of 14 Justice, Office of the Inspector General. New 15 York Field Office. Boston Area Office. This 16 interview with Federal Bureau of Prisons 17 Associate Warden - did I say that 18 correctly? 19 MS. : Yes. Correct. Mm-hmm. 20 MR. : Is being conducted as 21 part of an official U.S. Department of Justice, 22 Office of the Inspector General, or DOJ/OIG, 23 investigation. Today's date is December 2nd, 24 2021, and the time is 10:34 a.m. This 25 interview is being conducted by telephone. I EFTA00127207 LIMITED OFFICIAL USE 4 1 contacted you, Ms. by telephone number 2 (870) 494-4200, extension 4209. Also present 3 4 5 6 by telephone is DOJ/OIG Special Agent . This interview will be recorded by me, SSA . Could everyone please identify themselves for the record, and 7 spell your last name? To start, again, I am 8 DOJ/OIG Senior Special Agent 9 And my last name is spelled can you just state your name and 11 spell your name for the recorder? 12 : Yes. I am DOJ/OIG Special 13 Agent Last name is spelled II ■ 15 MR. : And Ms. 16 MS. : My name is 17 Associate warden. Last name is spelled E-D-G- 18 E. 19 MR. : Great. Thank you very 20 much. This is an official DOJ/OIG 21 investigation into the death of inmate Jeffrey 22 Epstein and the surrounding circumstances, and 23 you are being asked to voluntarily provide 24 answers to our questions. Will you agree to 25 the interview with the DOJ/OIG? EFTA00127208 LIMITED OFFICIAL USE 1 MS. : Yes. I do. 2 MR. : Perfect. And were you 3 able to review the voluntary interview form 4 that I sent to you via email, the DOJ/OIG form 5 11I-226/2? 6 MS. : Yes, I was. Yes, I did. 7 MR. : Perfect. And thank you 8 for sending it back to me a few minutes ago. I 9 see that you signed and dated it. 10 MS. : Mm-hmm. 11 MR. : And do you understand the 12 OIG form? 13 MS. : Yes, I do. 14 MR. : Perfect. And just, I'm 15 going to just going to read it for the record, 16 so that that's something that we have to do. 17 It says, United States Department of Justice, 18 Office of the Inspector General, Warnings and 19 Assurances to Employee Requested to Provide 20 Information on a Voluntary Basis. It says, 21 "You are being asked to provide information as 22 part of an investigation being conducted by the 23 Office of the Inspector General. This 24 investigation is being conducted pursuant to 25 the Inspector General Act of 1978, as amended. EFTA00127209 LIMITED OFFICIAL USE 6 1 This investigation pertains job performance 2 failure and security failure. This is a 3 voluntary interview. Accordingly, you do not 4 have to answer questions. No disciplinary 5 action will be taken against you if you choose 6 not to answer questions. Any statements you 7 furnish may be used as evidence in any future 8 criminal proceedings, or agency disciplinary 9 proceedings, or both." And there is a waiver 10 section. It says, "I understand the Warnings 11 and Assurances stated above, and I am willing 12 to make statements and answer questions. No 13 promises or threats have been made to me, and 14 no pressure or coercion of any kind has been 15 used against me." And I see that you signed 16 your signature. You printed your name, 17 And you dated and time 18 12/02/21, at 9:00 a.m. So, I assume that is 19 the time that you reviewed the form? 20 MS. : Yes. 21 MR. : Perfect. And that is 22 your signature on this form? 23 MS. : Yes, it is. 24 MR. : Awesome. And is there 25 any questions you have with regard to the EFTA00127210 LIMITED OFFICIAL USE 1 interview, or this form? 2 MS. : No. I don't. 3 MR. : Awesome. So, I will be 4 signing my name as the Special Agent. And 5 then, I will print my name under that as the 6 Special Agent. , do you mind - since this 7 is a telephone interview, you're not present - 8 do you mind if I sign for you, and place that 9 it was me that signed for you, and print your 10 name as the witness? 11 : I don't mind. 12 MR. : Perfect. All right. So, 13 I will sign for you, and then print your name, 14 and I will add the telephone number that we 15 are, as the place. Great. Let me get back to 16 this. Before starting the interview, I would 17 like to place you under oath. Ms. , can 18 you please raise your right hand? Do you swear 19 to tell the truth and nothing but the truth 20 during this interview? 21 MS. : Yes, I do. 22 MR. : Perfect. Thank you. And 23 then, because we are not in person, I'm just 24 going to have to ask you a couple questions to 25 verify your identity. What is your current EFTA00127211 LIMITED OFFICIAL USE 1 2 home address? MS. 4 MR. : Thank you. And what is 5 your date of birth? 6 MS. 7 MR. : And what is your social 8 security number? 9 MS. : Do I have to give it? 10 MR. : You can give me your last 11 four, if that's okay. 12 MS. : Okay. The last four. 13 MR. : Perfect. Thank you. And 14 how long have you worked for the BOP? 15 MS. : For 21 years. 16 MR. : Do you remember, 17 approximately, when your enter on duty date 18 was? 19 MS. : Yes. September 10 of 2000. 20 MR. : Perfect. And what is 21 your current position with the BOP? 22 MS. : I'm an Associate Warden. 23 MR. : And where is that? 24 MS. : I'm stationed at FCC Forrest 25 City in Forrest City, Arkansas. EFTA00127212 LIMITED OFFICIAL USE 1 MR. : And how long have you 2 held that position? 3 MS. : I've been - well, I've been at 4 this present duty station since officially 5 September, but physically here in October. Bu- 6 I've been an associate warden for, prior to 7 that. 8 MR. : Okay. So, you've been 9 basically you were remote in September, and 10 then physically present in October of this 11 current year, 2021? 12 MS. : Correct. 13 MR. : Perfect. And you - I'm 14 sorry - you said you've been an associate 15 warden since when? 16 MS. : I've been an associate warden 17 since - we're in 2021 - I think 2017. 18 MR. : Since 2017? 19 MS. : Uh-huh. 20 MR. : Okay. Great. And what 21 are your duties and responsibilities as an 22 associate warden? 23 MS. : As an associate warden, I 24 provide advice and counsel to the warden, and I 25 have oversight of specific disciplines as EFTA00127213 LIMITED OFFICIAL USE 1 decided by the warden. 2 MR. : Okay. 3 MS. : And I made decisions on policy, 4 and security (Indiscernible *00:06:34) concerns 5 of the institution. 6 MR. : Okay. And were you ever 7 interviewed by either the DOJ/OIG or FBI 8 regarding the Epstein matter? 9 MS. : No. I was not. 10 MR. : Okay. So, this is the 11 first time? 12 MS. : Yes. 13 MR. : Okay. Great. And are 14 you familiar with inmate Jeffrey Epstein, who 15 was housed within the MCC in July and August 16 2019, until his death on August 10th, 2019? 17 MS. : Yes. 18 MR. : And what was your 19 involvement with the matter? 20 MS. : Well, I have limited 21 involvement. I arrived at MCC New York July 22 4th, I believe, of 2019. And Epstein expired 23 August 10th, I believe. So, I actually, I saw 24 him, like, when he was in the visiting room. 25 And I was part of - there has been some EFTA00127214 LIMITED OFFICIAL USE 11 1 meetings, exec staff meetings. But as far as 2 extensive contact, or extensive involvement, 3 really nothing extensive due to my short time 4 being at the institution. 5 MR. : Okay. So, you did arrive 6 on July 4th? So, I guess you were there, then, 7 the entire time during his stay, though. 8 Correct? 9 MS. : Well, not the entire -. I 10 don't know when he arrived. So, I believe it 11 wasn't the entire time. But it was -. I think 12 he arrived some time in June, if I'm not 13 mistaken. I don't recall. 14 MR. : He arrived in July. 15 Right around the same time. So -- 16 MS. : In July? 17 MR. : -- there might be, like, 18 a day or two difference, but yeah, it was -- 19 MS. : Okay. 20 MR. : -- it was July and August 21 was when he was there. 22 MS. : Okay. Yeah. 23 MR. : Awesome. So, if you were 24 there in July, I'm just going to briefly touch 25 on the July 23rd, 2019 incident. Do you recall EFTA00127215 LIMITED OFFICIAL USE 1 an incident involving Jeffrey Epstein and 2 inmate Tartaglione on July 23rd, 2019? 3 MS. : When you say an incident, what 4 do you mean? 5 MR. : So, there was an incident 6 that happened in the SHU, where Tartaglione was 7 Epstein's celimate, and Epstein was removed 8 from the SHU and placed on suicide watch, and 9 then psychological observation. Are you 10 familiar with that? 11 MS. : Oh, yes. I'm familiar with it. 12 MR. : And what is your 13 understanding of what transpired? 14 MS. : My understanding is that 15 Tartaglione, I believe he requested, or he 16 called somehow for assistance because I believe 17 he indicated that Epstein was trying to commit 18 suicide. 19 MR. : Okay. And do you know by 20 what manner Epstein was attempting to commit 21 suicide? 22 MS. : I believe he was trying to, by 23 use of either strings, or some kind of 24 clothing, or something as a ligature. 25 MR. : Okay. And is it your EFTA00127216 LIMITED OFFICIAL USE 13 1 understanding that Epstein attempted to harm 2 himself? 3 MS. : Yes. That was my 4 understanding. 5 MR. : And did you hear anything 6 with regard to Tartaglione attempting to harm 7 Epstein? 8 MS. : I know there was, there was 9 speculation, not from Epstein, but there was 10 speculation that, perhaps, you know, there 11 could have been something involved, but 12 Epstein, I believe, made statements that his 13 cellmate did not try to harm him, as well as 14 Tartaglione himself indicated that he did not 15 try to harm him. 16 MR. : Okay. So, your belief is 17 that they are, they were not correct 18 statements, and then in fact it was Epstein 19 that attempted to harm himself, and not 20 Tartaglione? 21 MS. : That is correct. 22 MR. : Okay. And did you have 23 any involvement with selecting Tartaglione as 24 Epstein's cellmate? 25 MS. : No. I did not. EFTA00127217 LIMITED OFFICIAL USE 1 MR. : And do you know how 2 Tartaglione was selected to be Epstein's 3 cellmate? 4 MS. : I don't know. I don't, I don't 5 know exactly how he was selected. I do know, 6 after the fact, it was indicated that, because 7 he was former law enforcement, and he didn't 8 seem like he, I guess he didn't - he didn't 9 have anything that, it didn't appear that he 10 would hurt Epstein, that he was suitable to be 11 Epstein's cellmate. But I don't know exactly 12 what the vetting process was for that decision. 13 MR. : Okay. And do you believe 14 that Tartaglione was an appropriate choice for 15 a cellmate? 16 MS. : I'm not going to speculate 17 about that. I do know, at the time that he was 18 a cellmate, that he did not try to harm him. 19 Epstein never voiced any concerns about - that 20 I am aware of - about Tartaglione being his 21 cellmate. But as far as looking at 22 Tartaglione's charges, or anything to see if he 23 had any risk factors that would indicate that 24 he would harm Epstein, that would be 25 speculation after the fact. So, that, I don't EFTA00127218 LIMITED OFFICIAL USE 15 1 believe I'm in a position to make that decision 2 at this time. 3 MR. : Sure. Okay. And then, 4 what is your understanding of, after this 5 incident occurred, where was Epstein placed? 6 MS. : He was placed on suicide watch, 7 is my understanding. 8 MR. : Okay. Great. And that 9 was immediately following, or on July 23rd, 10 2019. Do you have any involvement with Epstein 11 while he was on suicide watch? And then, 12 psychological observation? 13 MS. : No. 14 MR. : And where is that 15 conducted? Or where was that conducted? 16 MS. : Where, in the suicide watch 17 cells, you mean? 18 MR. : Correct. Where would 19 have he been housed at the time? 20 MS. : Oh, yeah. The suicide watch 21 cells are on the, they are on the second -. 22 They are on the second floor. On the same 23 floor as the health services department. So, 24 around the corner, and it's down the hall from 25 psychology. From the psychology department EFTA00127219 LIMITED OFFICIAL USE 16 1 themselves. 2 MR. : Great. And where was the 3 SHU located in the MCC? 4 MS. : The Special Housing Unit is 5 located on the ninth floor. 6 MR. : Great. And while Epstein 7 was on suicide watch, and then psychological 8 observation, do you know if he was allowed any 9 visits, specifically any attorney visits, or 10 anything like that? 11 MS. : I do believe that he was 12 allowed to see his attorney. 13 MR. : And do you know if he did 14 see his attorney while he was on psychological 15 observation? 16 MS. : I don't know for certain if, 17 like, watch was - if it was the same day, but 18 am not for certain, 100 percent certain, but I 19 do believe that it did occur. It did occur. I 20 know he was He saw his attorneys very 21 often. Almost daily. And I don't believe that 22 there was any break in visits. So, I would, 23 would say that it probably did happen on the 24 same day that he was on suicide watch. 25 MR. : And how would that work? EFTA00127220 LIMITED OFFICIAL USE 17 1 If someone is on suicide watch, and then 2 psychological observation, how would they meet 3 with their attorneys? 4 MS. : Typically, if someone is on 5 suicide watch, they do not have visits, and 6 they don't - because they're on watch - they 7 would be under constant, whether it was an 8 inmate companion, or a staff watch. So, 9 typically, a person on suicide watch would not 10 have visits. So, if a visit did happen during 11 suicide watch, I would gather that that person 12 will still be under the same observation 13 protocol. Obviously, another inmate would not 14 be able to watch them because of the privacy 15 factor with the visit, but I would, I would 16 assume that a staff member would be present. 17 MR. : Okay. Now, would they be 18 present on that second floor suicide watch 19 area, psychological observation area? Or would 20 that be conducted in the attorney visit rooms 21 of the MCC? 22 MS. : So, again, typically, visits 23 don't happen when a person is on suicide watch. 24 And because of the placement where suicide 25 watch is, there is no visits that happen in EFTA00127221 LIMITED OFFICIAL USE 18 1 that area. So, all of the attorney conference 2 visits, they happen in the attorney conference 3 area, which is on the third floor. So, any 4 visit, attorney related, would happen on the 5 third floor, in the attorney conference area. 6 MR. : And to make sure I'm 7 understanding you correctly. So, that means 8 you believe that when Epstein was on 9 psychological observation or suicide watch, he 10 would have been, then, transported to that 11 third floor visiting area where he would 12 conduct his visits with his attorney? His 13 attorneys. 14 MS. : That is correct. 15 MR. : Okay. Now, were there 16 any specific - and oh, sorry, before I move on, 17 I guess I should say. So, that is not typical, 18 though? That would have been, like, a kind of 19 something that was a special circumstance for 20 Epstein? 21 MS. : Yeah. Yeah. That is not 22 typical. 23 MR. : Okay. And do you know if 24 there is any prohibition up against that, or 25 not? EFTA00127222 LIMITED OFFICIAL USE 19 1 MS. : I know There are 2 guidelines, I believe, that when a person is on 3 suicide watch, that is where they would remain 4 under constant supervision, and there would be 5 no visits. 6 MR. : Okay. So, I am assuming 7 that answer would be, then, yes, there are 8 prohibitions? 9 MS. : When you say prohibitions, you 10 mean that the agency has guidelines in place 11 that says absolutely not? 12 MR. : Yeah. So, I guess what 13 I'm asking is, should Epstein have been 14 visiting with his attorneys while he was on 15 suicide watch, or psychological observation? 16 MS. : If there was a determination, 17 which I am not aware of, that deemed that it 18 would be okay or appropriate, as far as a 19 psychologist, or someone from the psychology 20 department, indicating that it would be okay, 21 then that would be, you know, that would be a 22 consent. 23 MR. : Sure. 24 MS. : But other than that, I don't 25 believe anyone else would make that EFTA00127223 LIMITED OFFICIAL USE 1 determination to say that he would then be 2 taken off of suicide watch, and then placed in 3 the attorney conference area. 4 MR. : Okay. Great. So, I take 5 it, then, is it that MCC psychology department, 6 are they the ones who determined that Epstein 7 should be on suicide watch, and then 8 psychological observation? 9 MS. : Well, anyone can actually place 10 someone on suicide watch, if that person voices 11 - and when I say "anyone," for instance, if I 12 call, a psychologist is not there after hours, 13 someone voices an intent to harm themselves, 14 the lieutenant can make that decision to place 15 the person on suicide watch. But psychology 16 typically is the one that would determine 17 whether someone is taken off of suicide watch 18 because they would have to do a suicide risk 19 assessment, and any other clinical assessment. 20 So, placing someone on suicide watch 21 again - depending on the time, it can be 22 psychology, or it can be a correctional 23 services staff member. And then, the removal 24 would be someone from psychology, to say that 25 this person is not deemed suicidal, or, you EFTA00127224 LIMITED 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 OFFICIAL USE know, they are safe to be in general population. MR. : Okay. And then, but it would also - and correct me if I'm wrong - but it did sound like you said that it would have been psychology's decision to allow Epstein to visit with his attorneys while he was on suicide watch or psychological observation? MS. : No. I don't know if that was what actually occurred. But to remove someone from suicide watch, that would be a psychology decision. MR. : So, when you say "remove someone," do you mean, like, just for those hours that he was visiting, or are you talking about when he was removed and placed back in the SHU? MS. : Typically, when you remove someone, it's not for an hour or two. It's typically, you are saying that that person poses no more risk to themselves, so they are off. Basically, they are going back to general population. So, I am not aware of any situation where you remove a person for an hour or two, or for a short timeframe, and then EFTA00127225 LIMITED OFFICIAL USE 1 place them back. 2 MR. : Sure. So, that is kind 3 of I guess what I'm asking is, who makes the 4 determinations? Because you said that your 5 understanding was that he did conduct his 6 attorney visits during that time period that he 7 was on suicide watch. 8 MS. : Mm-hmm. 9 MR. : Or psychological 10 observation. So, who made the, you know, who 11 had the authority to allow him to conduct those 12 attorney visits? 13 MS. : Yes. I don't know. Again, I 14 don't know who made the ultimate decision for 15 that to happen. But I know the process for 16 removal of suicide watch, and what that process 17 entails. And that is why I'm saying, to remove 18 someone off of suicide watch, it would have to 19 be someone in psychology, to say that that is 20 appropriate. But in this instance, I don't 21 know, I don't know if that was communicated. 22 If that actually occurred. So, I hope, 23 hopefully that answers the question. 24 MR. : Sure. Yeah. 25 MS. : But (Indiscernible *00:19:29). EFTA00127226 LIMITED OFFICIAL USE 23 1 MR. : We can move on to the 2 SHU, then, when he got removed. So, do you 3 know if there were any specific instructions, 4 by either you, the warden, or other MCC 5 executive staff, with regard to Epstein being 6 placed back in the SHU from psychological 7 observation? 8 MS. : When he was - you are saying 9 when he was removed? 10 MR. : So, when a determination 11 was made that he - for Epstein to be removed, 12 which was on or about July 30th, 2019. 13 MS. : Mm-hmm. 14 MR. : Were there any specific 15 instructions provided by you, the warden, or 16 other MCC executive staff, with regard to 17 Epstein being placed back in the SHU? 18 MS. : Well, I didn't, I didn't have 19 any specific direction, or instructions to a 20 particular staff member. But I do, I do know 21 that there was a determination made, and who 22 exactly made that determination, typically, 23 when you - high-profile individuals, and you 24 are saying to place them in Special Housing for 25 their care, it is typically the CEO, the EFTA00127227 LIMITED OFFICIAL USE 1 warden, in consultation with correctional 2 services, because it falls under custody care 3 and control. And so, that decision was made to 4 place him in Special Housing. 5 MR. : Okay. Do you know, did 6 you, MCC executive staff, or anyone, including 7 the warden, receive any calls, or was anyone 8 contacted by lawyers, or a judge, asking for 9 Epstein to be removed from suicide watch or 10 psychological observation? 11 MS. : That, I am not aware of any 12 communication about that. 13 MR. : Okay. And just to circle 14 back. Were you, or executive staff, involved 15 with any decisions to have Epstein removed from 16 suicide watch or psychological observation? 17 MS. : Say that one more time. Say 18 that one more time. 19 MR. : So, that actually having 20 him removed. So, back on July, you know, 30th, 21 when he was removed. Would yourself or 22 executive staff, would you have been a part of 23 the process of actually taking him off of 24 suicide watch or psychological observation? 25 MS. : No. EFTA00127228 LIMITED OFFICIAL USE 1 MR. : So, that is solely a 2 psychology decision? 3 MS. : Yeah. Because they are the 4 subject matter experts, and again, and whether 5 someone is off of suicide, or displaying 6 suicide risk factors, typically, it is a 7 psychology thing, to remove the individual. 8 MR. : Okay. And that, that's 9 not in consultation with MCC executive staff? 10 MS. : No. To remove someone from 11 suicide watch? No. 12 MR. : Okay. Now, it is our 13 understanding that, after Epstein was placed 14 back in the SHU, or the Special Housing Unit, 15 psychology recommended that Epstein be housed 16 with a cellmate. Do you know if that is 17 accurate? 18 MS. : That, I do know that is 19 accurate. 20 MR. : You do know that it is 21 accurate? 22 MS. : Yes. That, I do believe that 23 that was - Mm-hmm - that is accurate. That it 24 was indicated that he should have a cellmate. 25 MR. : Okay. And do you know EFTA00127229 LIMITED OFFICIAL USE 26 1 how that information was disseminated within 2 MCC? 3 MS. : And again, there was several, 4 you know, there was meetings, and I don't know 5 what particular meeting it occurred, but I do 6 recall, during one of the meetings, that it was 7 indicated. I don't know if it was during close 8 out, or open up, that it was important that he 9 did have a cellmate. 10 MR. : Okay. So, it was an 11 actual requirement that Epstein have a cellmate 12 while he was assigned to the SHU? 13 MS. : Yes. 14 MR. : Okay. And do you know 15 who made -? Do you know who he was celled 16 with? Do you know what the name of his 17 cellmate was when he came back off of suicide 18 watch, on July 30th, 2019? 19 MS. : Oh, who was his cellmate? i 20 don't know if it was I don't know what the 21 (Indiscernible *00:23:19). But I do know, at 22 one point, he had a cellmate named - the last 23 name was Reyes. And the first name was Efrain. 24 E-F-R-A-I-N. But I don't recall if that was 25 his consistent cellmate. But I do recall, EFTA00127230 LIMITED OFFICIAL USE 1 besides Tartaglione, Reyes was another 2 cellmate. 3 MR. : And thank you. I have 4 actually been saying Efrain. So, it's Efrain? 5 MS. : That's what I think you 6 pronounce it as. It could be my New York 7 accent, but I'm saying Efrain. 8 MR. : Okay. Hey. That's - _ 9 guess -. Yeah. I'm looking at it, and it's -. 10 I'm going to start saying Efrain now. 11 MS. : Mm-hmm. 12 MR. : Do you know who made the 13 decision that Reyes would be Epstein's 14 cellmate? 15 MS. : That, I am not aware of. I 16 don't know if it was an actual, like, meeting, 17 as far as a placement decision. So, I don't 18 know if it was actually a vetting process, to 19 determine who should be the cellmate. I know 20 it was indicated that he should have a 21 cellmate. But what that process was, to get to 22 Reyes, I am not aware of it. 23 MR. : Okay. So, that means 24 that you were not involved with that decision? 25 MS. : No. EFTA00127231 LIMITED OFFICIAL USE 28 1 MR. : Okay. And did you work 2 at the MCC on August 9th - which was a Friday - 3 or August 10th - which was a Saturday - that he 4 was found in 2019? 5 MS. : Well, I worked on Friday. My 6 work hours, because of my position, I work 7 Monday through Friday, 7:30 to 4:00. But I did 8 report to the institution the morning of, when 9 I received the call indicating that I needed to 10 report to the institution on that day that 11 Epstein was found. 12 MR. : Okay. So, on Friday, 13 August 9th, you worked from 7:30 a.m. to 4:00 14 p.m.? 15 MS. : Correct. 16 MR. : And then, on August 10th 17 - so, you did depart at 4:00 p.m. - and then 18 you returned after Epstein was found on August 19 10th? 20 MS. : And then, I returned back to 21 the institution -. Okay. I'm trying to 22 remember what -. I received a call around 23 maybe 8:00 or something. I received a call, 24 and then, I arrived at the institution maybe 25 around 9:00 or so. EFTA00127232 LIMITED OFFICIAL USE 1 MR. : Okay. 9:00 a.m.? 2 MS. : Mm-hmm. 3 MR. : Okay. So, since Epstein 4 was required to have a cellmate, who was 5 ultimately responsible to make sure that all 6 SHU staff were aware of his cellmate 7 requirement? 8 MS. : Oh. Okay. And because - I'm 9 just going to say this - because it's Special 10 Housing, Special Housing is governed under 11 correctional services. It would be the captain 12 is typically in charge of correctional 13 services. And there is a SHU lieutenant that 14 is assigned to the Special Housing on a daily 15 basis. That that is that person's daily 16 assignment. And they are responsible for 17 ensuring that everything is in compliance in 18 Special Housing. And so, there should be some 19 communication, if then, like I said, psychology 20 made a decision that he had to have a cellmate. 21 Everyone was aware of it, but that, like, 22 verbal communication, or insurance, it should 23 have happened in the correctional services. 24 The captain. The lieutenant. And then, that 25 information communicated down to the staff that EFTA00127233 LIMITED OFFICIAL USE 1 actually work in the Special Housing Unit. 2 MR. : Okay. And do you know, 3 at the time, in August 9th and 10th, who the 4 captain at the MCC was? 5 MS. : It was 6 MR. : Okay. And do you know 7 who the SHU lieutenant at the time was? 8 MS. : That, I am not aware of. That, 9 I am not aware of. 10 MR. : Does Lieutenant 11 sound familiar to you? 12 MS. : I know Lieutenant . But I 13 don't know if that was his post at that 14 quarter. 15 MR. : Okay. 16 MS. : I am not sure. 17 MR. : Okay. So, that was his 18 post for the quarter. So, ultimately, the 19 information should have come from Captain 20 and SHU Lieutenant They should 21 have provided to the SHU staff that Epstein was 22 required to have a cellmate at all times? 23 MS. : Mm-hmm. 24 MR. : Okay. And that is a yes? 25 MS. : Yes. That is a yes. EFTA00127234 LIMITED OFFICIAL USE 31 1 MR. : Okay. Great. And how 2 should have they communicated that? Should 3 have that been verbally, in writing? How 4 should have they made sure everyone knew? 5 MS. : Now, to ensure that, you could 6 have a record of it if you put it in an email. 7 That's blatant, and that can never be 8 contradicted. You could also have verbal 9 notification, in addition to written 10 notification. So, that it could be both. 11 Honestly. It could be both. But if you have 12 it in - you have something that, a bulletin or 13 some kind of an email that went out, that's 14 definitely, you know, something that - that's a 15 record. That's a permanent record. 16 MR. : So, it sounds -- 17 MS. (Indiscernible *00:28:24) 18 MR. : -- like you're saying, it 19 really should have been both verbal and in 20 writing, but writing would basically make sure 21 that you are, it's documented? 22 MS. : Correct. 23 MR. : Is that a correct 24 understanding? 25 MS. : That is a correct EFTA00127235 LIMITED OFFICIAL USE 1 understanding. 2 MR. : Okay. 3 MS. : And in addition to that, I do 4 know that the SHU staff did know that he should 5 have had a cellmate. 6 MR. : You do know that they 7 knew that? 8 MS. : I do know that the SHU staff 9 knew that. Mm-hmm. 10 MR. : And how do you know that? 11 MS. : Because the staff are required 12 to make weekly rounds, and I don't -. Now, 13 because of, after the - excuse me - after the 14 fact, you know, he was kind of, like, you are 15 playing a - I'm just trying to recall the facts 16 - but I do recall instances of making rounds in 17 the Special Housing, where staff, it was said, 18 make sure that he had a cellmate, and when we 19 make rounds, that that was - I can - I verbally 20 heard folks say it myself. 21 MR. : And do you remember who 22 was engaged in those conversations, or who you 23 know specifically that knew? 24 MS. : That, I can't recall, because 25 in Special Housing, there is, like, four -. EFTA00127236 LIMITED OFFICIAL USE 33 1 There is -. You have the SHU number one, SHU 2 number two, the three, and the four. So, you 3 at least have four staff, and you have staff 4 that are SHU rec staff. So, there is several 5 staff assigned to the Special Housing Unit. 6 So, and at that -. So, I can't say with 7 certainty who was engaging in a conversation. 8 And then, like I said, and then you have the 9 SHU lieutenant. So, it was several folks that 10 were assigned to the Special Housing. And 11 again, I don't know specifically who said what, 12 but I do know that it was known because I 13 verbally, I heard it, it was audible. I heard 14 it. 15 MR. : While you were in the 16 SHU? 17 MS. : While I was in the SHU. 18 MR. : And do you know around 19 what time of day that would have been? 20 MS. : No. 21 MR. : No? 22 MS. : Hmm-mm. 23 MR. : And did you hear it more 24 than one time? 25 MS. : Yes. Mm-hmm. EFTA00127237 LIMITED OFFICIAL USE 34 1 MR. : So, it was something that 2 you had heard on multiple occasions? 3 MS. : Mm-hmm. 4 MR. : Okay. 5 MS. : Mm-hmm. 6 MR. : And is that something 7 that, because you were engaged in a 8 conversation, or you just overheard people 9 saying it? 10 MS. : I wasn't engaging in the 11 conversation about Epstein per se, but just in 12 a conversation about what was going on in SHU, 13 while making rounds. 14 MR. : Okay. 15 MS. : So, you discuss -. So, 16 typically, when you make SHU rounds, you can do 17 both. You can have, like, a SHU roster that 18 kind of lists all of the inmates that are 19 housed in the SHU. You can, like, look at the 20 board to see who has cellmates. So, sometimes, 21 the conversation is prompted from multiple 22 things, or sometimes inmates stop you at the 23 door, and ask questions, and then you talk 24 about who it is that asked you questions. So, 25 I'm just saying, because of all those EFTA00127238 LIMITED OFFICIAL USE 35 1 instances, I don't know why it was said about 2 that particular thing, but that was, that was 3 just one of some comments during that day. 4 MR. : But it was a comment 5 specific -- 6 MS. : Yeah. 7 MR. : -- to Epstein's cellmate. 8 Correct? 9 MS. : Yes. Exactly. 10 MR. : Okay. And do you know if 11 there were any plan -. Or sorry. Before I 12 move on, I guess I should specifically ask you. 13 So, you mentioned there was SHU one, two, 14 three, four, but Epstein was found when, you 15 know, during the overnight, I guess the morning 16 watch, which is, you know, I think midnight to 17 8:00 a.m. 18 MS. : Mm-hmm. 19 MR. : He was found at 20 approximately 6:33 a.m. on August 10th, and 21 then, at that time, there were only two SHU 22 staff in there. 23 MS. : Mm-hmm. 24 MR. : Specifically, a 25 and a . Do you know those two EFTA00127239 LIMITED OFFICIAL USE 1 staff members? 2 MS. : I know of them. 3 MR. : Do you know if either of 4 those two specific staff members were aware of 5 Epstein's cellmate requirement? 6 MS. : No. I don't -. That, I don't 7 know because they are assigned to work other 8 departments, and they were working overtime. 9 But what I do know - because I also, when i 10 first started working in the Bureau, I was a 11 correctional officer - I do know that you 12 should engage in conversation with whomever it 13 is that you are relieving, to find out, is 14 there any special precautions, or you pass on 15 your equipment, you talk about what your base 16 count is. So, there, there should be some 17 communication between you and the staff member 18 that you are relieving. 19 MR. : Now, do you believe, if 20 the person's quarterly assignment was the SHU, 21 they would have known, and should have known? 22 MS. : Yeah. Yes. 23 MR. : Okay. So, if you know 24 that Tova Nova was actually assigned to the SHU 25 for that quarterly post, does that change EFTA00127240 LIMITED OFFICIAL USE 1 anything for you? 2 MS. : Hmm. Well, you said 3 Was she an officer, or she was -- 4 MR. : She was an officer. 5 MS. was she -? 6 MR. : But she was assigned -- 7 MS. : Okay. 8 MR. : -- as her quarterly -- 9 MS. : Mm-hmm. 10 MR. : -- post was in the SHU. 11 12 MS. : Okay. 13 MR. : -- was on overtime, 14 working in the SHU. He was a materials 15 handler. 16 MS. : Okay. 17 MR. : But was 18 actually -- 19 MS. : Okay. 20 MR. : -- assigned to the SHU. 21 MS. : Okay. Well then, she should 22 have known. And then, she - and again, I 23 didn't delve into that - she was on overtime, 24 but was she responding to what shift? Like, 25 evening watch? Was that her permanent EFTA00127241 LIMITED OFFICIAL USE 38 1 assignment? 2 MR. : I would have to check if 3 that was her -- 4 MS. : Okay. 5 MR. : -- she may have been, you 6 know, you might, you may be right. 7 MS. : Mm-hmm. 8 MR. : She may have been working 9 overtime in the SHU, but she was, in fact, 10 assigned to the SHU -- 11 MS. : Okay. 12 MR. : -- for that quarter. 13 MS. : Then she should have known. 14 MR. : And do you believe 15 MS. : She should have. 16 MR. : -- that there is any 17 excuse for her to say that she didn't know? 18 MS. : I can't see how, if that is 19 your post for the quarter, that you would not 20 know, because you have to make decisions based 21 on, like, recreation. You have to do rounds. 22 You have to actually physically walk down the 23 range. There are name tags on the door. There 24 is the hot list. There is information that 25 psychology, at times, even sends out to SHU EFTA00127242 LIMITED OFFICIAL USE 39 1 staff, indicating these inmates are on the hot 2 list, or these are some important factors about 3 specific inmates. 4 So, there is, there is information, and 5 there is things that you are required to do, as 6 part of your assignment in SHU, that you would 7 have to know who can even go in recreation, in 8 the recreation cage, with whom. It's because 9 of separation. So, there is information that 10 you have to be able to, you have to know, in 11 order for you to make safe decisions during 12 your eight hours of having oversight over the 13 inmates. 14 MR. : So - great - so, you 15 touched on the hot list. Can you just very 16 briefly explain what the hot list is? 17 MS. : Well, the hot list is, it's, 18 like a list that kind of, that psychology puts 19 together, and it has information about, at 20 times, who is on suicide alert, or of any kind 21 of risk factors, or something that requires 22 special care for just specific inmates. So, it 23 is, your base count, or the SHU can help maybe 24 have the capacity to hold maybe 80 inmates, 25 right? And if - not everyone is on the hot EFTA00127243 LIMITED OFFICIAL USE 1 list. 2 MR. : Okay. 3 MS. : So, again, the hot list is just 4 specifically designed to highlight specific 5 inmates, and what is needed, or something 6 special about that specific inmate. 7 MR. : So, if an inmate comes 8 off of suicide watch, or psychological 9 observation, and is placed in the SHU, would he 10 be - he or she, yeah - would he be listed on 11 the hot list? 12 MS. : I don't know if that would be 13 on the hot list, but I know that that should be 14 - that is something that would probably be on 15 the SHU roster, or the SHU report. 16 MR. : Okay. 17 MS. : The SHU report, it lists all of 18 the inmates. It has pictures of all of the 19 inmates. And it also sections for health 20 services, for psychology, for correctional 21 services, and for unit teams. And in those 22 comment sections, they typically will say this 23 inmate may need a cellmate. This inmate is on 24 the hot list. This inmate should be kept away 25 from inmate X, Y, and Z. It provides specific EFTA00127244 LIMITED OFFICIAL USE 41 1 information. So, even if it was not on the hot 2 list, it probably would also be on the SHU 3 report, which is BOPWARE. That's an electronic 4 report that you can pull from a program, a BOP 5 program. 6 MR. : Okay. Now, do you know, 7 though, if Epstein specifically was on the hot 8 list in August of 2019? 9 MS. : You know what? I don't know 10 that. 11 MR. : Okay. So, if he was, 12 though, would it have listed that he was 13 required to have a cellmate? 14 MS. : I'm trying to think if that 15 information would be on the hot list. I'm not 16 sure if that information would be on the hot 17 list. 18 MR. : But it would be on this 19 other report that you were just speaking of, 20 that's in BOPWARE? 21 MS. : I was - mm-hmm - that should, 22 that is something that would be important, that 23 psychology would definitely put on there. 24 MR. : And would be - 25 would have she had been required to review that EFTA00127245 LIMITED OFFICIAL USE 42 1 list, and see that Epstein was required to have 2 a cellmate? 3 MS. : Well, you are not required to 4 review the list, but in order to know what's 5 going on with the inmate, I mean, you have to 6 have a SHU roster. You would have to know 7 what's going on with the inmates. 8 MR. : So -- 9 MS. : So -. 10 MR. : -- so, she should have 11 reviewed the list, is what you are saying? 12 MS. : If you want to know what's 13 going on with the inmates, I would say that you 14 would review your SHU report. 15 MR. : Is there any other ways 16 that , being that it was her quarterly 17 post, would have and should have known that 18 Epstein was required to have a cellmate? 19 MS. : I do also know that we have 20 TruScope. So, there is also an electronic 21 program called TruScope, and psychology lists 22 things, and that psych, it's called a 23 psychology advisory list. And so, again, there 24 is multiple electronic formats. And paper 25 formats and things that information is listed. EFTA00127246 LIMITED OFFICIAL USE 1 MR. : Okay. 2 MS. : So -. 3 MR. : And do you know, were 4 there any plans made on how to address the 5 situation if Reyes was removed as Epstein's 6 cellmate? 7 MS. : I do - hmm - I don't recall 8 there being a meeting to say specifically if 9 Reyes was removed, but -. So, I can't say that 10 there was a meeting that I am aware of, to talk 11 about. 12 MR. : So, being that Epstein 13 was -- 14 MS. : Actually, (Indiscernible 15 *00:39:13). 16 MR. : -- so, being that Epstein 17 was required to have a cellmate, and being that 18 MCC is, you know, a jail versus a prison, where 19 prisoners are constantly moved in and out. 20 MS. : Mm-hmm. 21 MR. : Was there anything in 22 place to address that situation, if Epstein is 23 required to have a cellmate, his cellmate is 24 then removed. What should have happened? 25 MS. : I don't recall of a EFTA00127247 LIMITED OFFICIAL USE 44 1 conversation specific to that. But I do know, 2 as part of, not just Epstein, but any inmate, 3 if they are required to have cellmates, if you 4 are doing your rounds, and the cellmate is not 5 in there, it could be because that cellmate is 6 inside of the recreation cage, but if it is a 7 prolonged thing -- 8 MR. : Mm-hmm. 9 MS. : -- that is something that 10 should be brought to the attention of, 11 obviously, your first line supervisor first, 12 and then that supervisor would then call, 13 depending on if it is after hours, they can 14 call the on-call psychologist, or if it during 15 duty hours, you call - then the lieutenant 16 would then contact someone in psychology. 17 MR. : Okay. So, the supervisor 18 19 MS. : Mm-hmm. 20 MR. : -- you're saying is the 21 SHU lieutenant. So, SHU staff should have 22 notified the SHU lieutenant? 23 MS. : Yes. 24 MR. : Now, what -- 25 MS. : Mm-hmm. EFTA00127248 LIMITED OFFICIAL USE 45 1 MR. : -- what about if the SHU 2 lieutenant is off? So, on the 9th, Lieutenant 3 is off that day. There is no SHU 4 lieutenant. What should have happened with SHU 5 staff? Who should have they contacted? 6 MS. : There is always a lieutenant. 7 So, even if , who is the SHU lieutenant, is 8 not physically there, there is always a 9 lieutenant in the building, 24 hours. 10 MR. : Sure. 11 MS. : That person is -. So, there is 12 the management official, after hours. And so, 13 when there is any kind of emergency, or an 14 inmate situation that rises to the level of 15 contact, there is a management official there. 16 And they have received calls. And they then 17 call the captain, and then, the captain can 18 determine whether or not he wants some, you 19 know, to increase the level and call the AW, 20 but there is always a lieutenant in the 21 institution. 22 MR. : Okay. And so, they 23 should have contacted one of the lieutenants, 24 and you are referring to the two lieutenants 25 that are usually there during the day. Can you EFTA00127249 LIMITED OFFICIAL USE 46 1 refresh my memory of what the two are called? 2 MS. : One is the operations, and one 3 is the activities lieutenant. 4 MR. : Right. So, is there one 5 or the other that the SHU staff, during the 6 day, should have called? 7 MS. : Well, during the day, now, 8 okay, Monday through Friday, during the day, 9 there is the SHU lieutenant. 10 MR. : No. I'm saying on the 11 9th -- 12 MS. : After -. 13 MR. : -- with the fact that the 14 SHU lieutenant is not there. 15 MS. : That you can call, you can 16 either call the activities or operations. 17 MR. : So, it is either or. 18 There is not -- 19 MS. : But one -- 20 MR. : -- one or the other? 21 MS. : -- hey, you can call Hmm- 22 mm. You can call either or. 23 MR. : Okay. Great. And do you 24 know what happened to inmate Reyes on August 25 9th, 2019? EFTA00127250 LIMITED OFFICIAL USE 47 1 MS. : I know, I know because of after 2 the fact, that he was, I believe he was bonded, 3 or somehow, he was released from court. He was 4 at court, and he never came back because of 5 either a bond, receiving a bond or a bail. 6 MR. : Okay. So, your 7 understanding is that he actually went to 8 court, and then was released? 9 MS. : Yes. That is my understanding. 10 MR. : And where did you receive 11 that information? 12 MS. : That is after the fact. After, 13 you know, trying to gather what happened, and 14 to his cellmate. And so, if the information 15 was not, I was not aware of the information on 16 the day. It's because of this incident that 17 am aware of the information. 18 MR. : Okay. So, and that is 19 your belief to this day? 20 MS. : Yes. That is my belief to this 21 day. 22 MR. : Okay. And what does WAB 23 mean? 24 MS. : Oh, that means With All 25 Belongings. EFTA00127251 LIMITED OFFICIAL USE 1 MR. : So, if a person is 2 transported down to Receiving and Discharge, 3 with the status WAB next to their name -- 4 MS. : Mm-hmm. 5 MR. : -- what does that mean is 6 happening? 7 MS. : That means that the inmate is 8 leaving, and he's not coming back. 9 MR. : So, it does mean that 10 they are actually - that that is known as that 11 inmate is not coming back to the MCC? 12 MS. : Correct. 13 MR. : And what is -- 14 MS. : Mm-hmm. 15 MR. : -- what is the document 16 that would say WAB on it? 17 MS. : Normally, there is a court 18 roster that lets the unit officer know that the 19 inmate is leaving. So, you would know who to 20 send down to R&D. And typically, it has an 21 approximate time. And/or, sometimes R&D may 22 then call up to the specific location, or the 23 housing unit, to say, send inmate so and so 24 down with all belongings. 25 MR. : Okay. So, but there is EFTA00127252 LIMITED OFFICIAL USE 1 a, it sounds like a court list, or a 2 production, an inmate production list that is 3 created by R&D? 4 MS. : That is correct. 5 MR. : And that is what would 6 say -? That is how -? What staff members 7 would utilize in order to produce the inmates 8 to R&D? 9 MS. : That is - yeah - that is my 10 understanding. 11 MR. : And what happens with 12 that document? Like, so, the staff members 13 utilize it, then where does the document go? 14 Is it saved somewhere, like BOPWARE, or 15 TruScope, or is it something that they print 16 out, and then they destroy, or do they keep it? 17 MS. : Well, I know that R&D 18 definitely should have a copy of the court 19 roster. They should. Now, as far as what the 20 housing unit would do with it, I would believe 21 that they probably would shred it because it 22 serves no purpose to that specific housing 23 unit. But R&D would maintain copies of the 24 court roster. 25 MR. : Now, if R&D is saying EFTA00127253 LIMITED OFFICIAL USE 50 1 that they actually don't keep a copy, it's like 2 a template that they revise every day, based 3 upon what inmates need to be produced. So, 4 they actually don't have any records from past, 5 you know, production lists. Does that sound 6 accurate to you? 7 MS. : Hmm. From my understanding, I 8 would think that a copy would be maintained. 9 And that there would also possibly be a 10 logbook. Because I - again - at the time, I'm, 11 you know, an associate warden, but, and I never 12 specifically worked in Receiving and Discharge. 13 But from my understanding of being in Receiving 14 and Discharge, and from our early, my early 15 years of being a correctional officer, I am 16 aware of, like, if a receipt is being 17 maintained, because someone keys in inmates in, 18 and keys inmates out in Sentry. And there, at 19 times, control even annotates things in their 20 daily, their daily log. 21 MR. : Yeah. 22 MS. : So, of, like, of movement. 23 Depending on the control room officer, that 24 officer may even take the time to list the 25 names, to actually write out names and register EFTA00127254 LIMITED OFFICIAL USE 1 numbers. Or they just might write out the 2 numerical value of how many inmates departed 3 for court, versus how many departed, like, with 4 all belongings. Because that means that the 5 inmate is not returning, and he would 6 definitely have to be taken off your base 7 count, in order to get an accurate count. 8 MR. : Okay. So, and I know 9 we're not in person, so I'm going to have to 10 just explain to you what I'm looking at. i 11 have two emails that were sent to the MCC. One 12 was to - both from the U.S. Marshals Service - 13 one was to just Receiving and Discharge 14 personnel, and another one was sent, it looks 15 like to, like to a large amount of custody 16 personnel, including lieutenants, it looks like 17 Tijuana , who I believe was the SIS 18 lieutenant. It looks like , who was an AW, is on there. As well as 20 a number of other people. Quite a large number 21 of people. I do not see your name on here. 22 But it does say the subject, "Prisoner 23 Production 8/9/2019," the date is Thursday, 24 August 8th, 2019, at 3:36 p.m. 25 MS. : Mm-hmm. EFTA00127255 LIMITED OFFICIAL USE 1 MR. : Now, within the 2 attachments, it shows NYM 8/9/2019. Do you 3 know what that would stand for? 4 MS. : You said NYM 8/9? 5 MR. : Yeah. So, N-Y-M. 6 MS. : Mm-hmm. 7 MR. : Yeah. And then, when you 8 open it up, it just says - it's the U.S. 9 Marshals report - and it says, "Prisoners 10 Schedule Report." It says -- 11 MS. : Mm-hmm. 12 MR. : -- MCC New York. 13 MS. : Mm-hmm. 14 MR. : Do you know if that would 15 be who was being produced to the U.S. Marshals 16 the following day? 17 MS. : Yeah. That is what it is. 18 It's a court list. 19 MR. : Okay. 20 MS. : Yeah. Basically, it's a court 21 list. 22 MR. : Okay. So, when I open 23 this up, on the first page there, it starts 24 with two inmates. The second inmate down, it 25 says, "Reyes, Efrain." Or Efrain. E-F-R-A-I- EFTA00127256 LIMITED OFFICIAL USE 1 N. 2 MS. Mm-hmm. 3 MR. : It shows a date of birth. 4 A time. A time. The time says 8:53, and then, 5 it says, 8/9/2019. Underneath production 6 reason, it says, "TF," and the description 7 says, "Transfer within." And then -- 8 MS. : Mm-hmm. 9 MR. : -- it says, "MCC New 10 York." And then, it does say, next to that, 11 typed court. Now, under that, it says, "Judge. 12 MCC TOT GEO." Do you know what that would 13 stand for? 14 MS. : No. I'm not. Hmm-mm. 15 MR. : So, the MCC to GEO. You 16 wouldn't understand that that -- 17 MS. : Oh. 18 MR. -: -- meant -? 19 MS. : Oh. GEO. MCC to GEO. That 20 means that GEO is a private prison. 21 MR. : Correct. 22 MS. : So, I would think that GEO, 23 that's, like - yeah - that's a mnemonic for a 24 private prison. 25 MR. : Okay. And then, when it EFTA00127257 LIMITED OFFICIAL USE 1 says, "Destination description," it says, 2 "WAB/MED summary." Does that tell you 3 anything? 4 MS. : Yeah. Well, WAB. WAB means 5 With All Belongings. Now, /MED summary means 6 medical summary. So, when I'm first hearing 7 you say WAB, that lets me know that the person 8 is leaving. That means with all belongings. 9 So, typically, when someone is scheduled for 10 transfer, you have the time to pack them out, 11 and so, they would come down, you know, prior 12 to the date. But with WAB, that means that the 13 person is leaving that day, and then they 14 should come down with all of their belongings. 15 Everything that they have because for whatever 16 reason, they're not coming back, they're going 17 somewhere else. 18 MR. : Right. So -- 19 MS. : And then -. 20 MR. : -- so, it looks like -- 21 MS. : Mm-hmm. 22 MR. : -- these first two 23 people, the first two people both say, 24 "Transfer within." Both of them say MCC to 25 GEO. And then -- EFTA00127258 LIMITED OFFICIAL USE 1 MS. : Mm-hmm. 2 MR. : -- they both say WAB, 3 with the destination in the description. Now, 4 the other inmates that are listed on here, they 5 have various things -- 6 MS. : Mm-hmm. 7 MR. : -- from the reason being 8 status hearing, to sentencing, to a change of 9 plea, to all things that look like they are 10 court related, but would you believe that these 11 first two, since it would say, "Transfer Within 12 MCC to GEO," and WAB, that means that they are 13 actually being transferred and not going to 14 court? 15 MS. : Yeah. I would - if I had an 16 opportunity to see that - I would understand 17 that that means that, exactly what you said, 18 that they are transferring. 19 MR. : Okay. 20 MS. : Somewhere other than -. 21 MR. : So, being that the MCC 22 was sent, actually, the one that was sent to 23 Receiving and Discharge was much earlier in the 24 day. But the one that was sent to the custody 25 was on August 8th, 2019 at 3:36 p.m. What EFTA00127259 LIMITED OFFICIAL USE 56 1 should have been known from that information? 2 MS. : That those inmates listed for 3 departing and were not coming back. 4 MR. : Okay. 5 MS. : Yeah. 6 MR. : So then, it was known by 7 the MCC, at least, or at least should have been 8 known by the MCC, that on August 8th, 2019, 9 that Reyes, who happens to be Epstein's 10 cellmate, was actually transferring from the 11 MCC to another institution. And specifically, 12 to GEO. 13 MS. : That part is accurate. The 14 only thing that is not included in that is, if 15 it was sent to R&D, and R&D may not have known 16 that Reyes was Epstein's cellmate. So, it may 17 not have alerted them that Reyes was 18 (Indiscernible *00:52:03) for them to then have 19 to discuss, to say, oh, he's not, you know, it 20 wouldn't have rang alarms for whomever that R&D 21 staff member was. 22 MR. : Right. And that's why 23 focused on the email to custody, because all of 24 custody, including all the lieutenants -- 25 MS. : Yeah. EFTA00127260 LIMITED OFFICIAL USE 57 1 MR. : -- as well as Shirley, or 2 AW , and Captain 3 were actually sent -- 4 MS. : Yeah. That -- 5 MR. : -- that email. 6 MS. okay. Then that is - yeah 7 that is different. That is different. 8 MR. : So, the fact that custody 9 received it, is there someone that should have 10 been alerted to the fact, or reviewed that 11 document, to know, huh, we got these two 12 inmates, one of them is Epstein's cellmate. 13 You know, we now know that Reyes is leaving 14 from the institution. Is there someone that 15 should have been responsible for catching that? 16 MS. : The one thing I will say is 17 that, unless you are actually looking at the 18 court production list, to vet it, a person may 19 have just seen that as another court production 20 list. If it wasn't actually read, to see, you 21 know, for - to determine, okay, this inmate is 22 leaving, and who is he associated with? 23 MR. : Absolutely. 24 MS. : So -- 25 MR. : And that's kind of - and EFTA00127261 LIMITED OFFICIAL USE 1 I apologize if I 2 MS. : -- no. 3 MR. : I apologize if I 4 wasn't clear. What I'm saying is -- 5 MS. : Mm-hmm. 6 MR. : -- should someone have 7 reviewed it? Is there someone that should have 8 - being that it was sent to all these people in 9 custody - is there someone that really should 10 have looked at it -- 11 MS. : Mm-hmm. 12 MR. : -- as opposed to could 13 have looked at it? 14 MS. : Yeah. No. That's not 15 necessarily the responsibility of custody to 16 view -. There is -. I will say this. There 17 is no procedures in place, or their 18 responsibility that exists, that would say that 19 custody had to review a court production list. 20 Typically, they don't -. They may have 21 received a list as a courtesy. But okay. It's 22 a courtesy. It wasn't necessarily something 23 that they may or may not have to have some, you 24 know, to do something with the list. It's not 25 EFTA00127262 LIMITED OFFICIAL USE 1 MR. : Okay. 2 MS. : -- it's just a courtesy. It's 3 nothing more than that. 4 MR. : Okay. Now, I have an 5 email here, it's from you to 6 Do you know who that is? 7 MS. . Yes. He was 8 the former warden. 9 MR. : Okay. Great. And the 10 subject, it says, "Epstein, Jeffrey Edward," 11 and then it gives his reg number. It was sent 12 Saturday, August 10th, 2019, at 4:35 p.m., and 13 in the body of the message, it says, "So far, 14 this is the documentation I have in my 15 possession." And it's signed your name, 16 Associate Warden, MCC New York." 17 So, do you recall if you were tasked with 18 obtaining documentation on Warden 19 behalf? 20 MS. : He didn't specifically task me 21 with anything. I just know that, when 22 something happens, that part of your 23 responsibility as an AW is to try to gather 24 documents. Now, I didn't have a specific 25 responsibility of securing the scenes. If EFTA00127263 LIMITED OFFICIAL USE 60 1 that's correctional services, and that is what 2 they do. But I, certain things, I just 3 inherently, or instinctively, knew that I 4 should try to assist with. But I wasn't given, 5 you know, the instruction that Warden 6 did, relayed to me was to report to the 7 institution because of, you know, the death. 8 And from that, I already knew, or in my head, 9 on the way there was planning of what I wanted 10 - one of the things that I needed to do to 11 assist with the matter. 12 MR. : Okay. So, you 13 independently took this task on, to collect all 14 these documents? 15 MS. : I did. 16 MR. : Okay. 17 MS. : I must admit I did. 18 MR. : Okay. Great. So, I have 19 the document opened that you provided to him. 20 It's an attachment to your email saying what it 21 was that you collected. 22 MS. : Mm-hmm. 23 MR. : It starts with, 24 "Documentation re: Epstein, Jeffrey -- 25 MS. : Mm-hmm. EFTA00127264 LIMITED OFFICIAL USE 1 MR. : -- Jeffrey Edward, 2 Deceased." And then, it talks about Sentry 3 reports. Like, the PPE-44, or PPE-37, and all 4 the way down to a PR-15. And then, it talks 5 about BOPWARE, label, administrative detention 6 order. And then, a few down, which is directly 7 in the middle of the first page, or slightly 8 below the middle, it shows, "Court 9 documentation regarding WAB." And this is 10 under -- 11 MS. : Okay. 12 MS. : -- under the heading, 13 "Documentation -- 14 MS. : Okay. 15 MR. : -- re: Efrain, Reyes. 16 Reg number 85993-054." And then, it says, 17 "Cellmate." It says, "Court documentation 18 regarding WAB, 8/9/19." Do you know what court 19 documentation is you were referring to? 20 MS. : Well, it had to be the court 21 list, then. Is it the same thing that -? Are 22 you able to open the attachment? 23 MR. : That is the attachment. 24 So, it doesn't -. You didn't include in that 25 email the electronic versions of this. You EFTA00127265 LIMITED OFFICIAL USE 1 said, this is what I have collected. 2 MS. : Oh. 3 MR. : And within it, it says -- 4 MS. : Okay. 5 MR. : -- "Court documentation 6 regarding WAB, 8/9/19," and specific to Efrain 7 Reyes. So, I am just wondering, what 8 MS. : Okay. 9 MR. : -- what document were you 10 referring to? 11 MS. : What document? It had to -. 12 Hmm. I don't know. Unless I'm able to 13 actually look at my email. But if you are 14 saying WAB, that means I had to have seen 15 something -- 16 MR. : If you are actually 17 MS. : -- that says that -. 18 MR. if you are in front of 19 your email, you can find this. Just go to your 20 sent emails. 21 MS. : Yeah. I have to go - hold on. 22 That's what I'm doing - but I have to go in my 23 archives. 24 MR. : Right. 25 MS. : You know? EFTA00127266 LIMITED OFFICIAL USE 1 MR. : Okay. So, yeah. 2 MS. : But when I open -- 3 MR. : This might help refresh 4 your memory, so we can actually, you can 5 actually look at what it is that I am talking 6 about. 7 MS. : Okay. 8 MR. : So -- 9 MS. : Yeah. 10 MR. : -- again, it would be, it 11 will probably take a little while -- 12 MS. : Okay. 13 MR. : -- because it was a long 14 time ago. 15 MS. : Yeah. 16 MR. : But August 10th, 2019 -- 17 MS. : Mm-hmm. 18 MR. : -- and again, the email 19 was sent at exactly 4:35 p.m. 20 MS. : Okay. Give me one second, 21 because like I said, I have to go in the 22 archives. 23 MR. : Sure. 24 MS. : Okay. Okay. To 25 MR. : And did you happen to get EFTA00127267 LIMITED OFFICIAL USE 1 to that email yet? 2 MS. : No. Hmm-mm. 3 MR. : Okay. 4 MS. : But the way that this -. Okay. 5 Hold on. Just wait. I got this. Okay. You 6 said -. Hmm. Not -. I'm doing an advanced 7 search. And because it's the archives, it's a 8 little slow. It's not -. It's not on my 9 present Google Drive. 10 MR. : Yeah. No. I understand. 11 Same thing when I look for my own emails. If 12 it's, like, more than six months to a year old 13 14 MS. : No. 15 MR. : =- it takes a while. 16 MS. : Okay. Now - okay - I'm in old 17 stuff now. Okay. You said 8/9, 8/10/19. Oh. 18 MR. : 11. 19 MS. : Okay. I'm in nine. That's why 20 I had to do with it. Okay. Okay. Okay. I 21 see. I see the Word attachment that is there. 22 Okay. 23 MR. : Okay. You did find the 24 email? 25 MS. : I - yes - I was able to find EFTA00127268 LIMITED OFFICIAL USE 1 the email. 2 MR. : Great. 3 MS. : Mm-hmm. 4 MR. : So then, yeah. So, you 5 see where the Word attachment. Do you see, 6 again, middle of the page, where it says, 7 "Documentation, Re: Reyes, Efrain." 8 MS. : Yeah. 9 MR. : And that - yeah - that 10 first document is the one I was wondering 11 about. This court documentation regarding WAB, 12 8/9/19. 13 MS. : Mm-hmm. 14 MR. : And I'm just trying to 15 refresh, see if you can remember what document 16 you would have -- 17 MS. : What -- 18 MR. : -- been talking about. 19 MS. : -- what I could do is, hold on, 20 because I'm trying to -. I'm trying to over 21 document that I have. Okay. So, what -. Let 22 me first forward this to my present email, so I 23 won't lose it. And then, I'm going to go, 24 because I had a folder of documents that I did 25 maintain because of that, I kept receiving, EFTA00127269 LIMITED OFFICIAL USE 66 1 like, inquiries after as to what documents I 2 had. And so, let me see what I -. See if I 3 have anything that shows that. Okay. Hold on. 4 I'm going to have go out Okay. So, I have 5 -. Okay. One thing I had, that I have a title 6 for Efrain was just, like, was his 7 (Indiscernible *01:04:43) and Sentry 8 information. Special Housing review. Okay. 9 That's not showing me the court date. R&D. 10 Okay. Hold on one second. Let me see which 11 drop file. No. The drop file. (Indiscernible 12 *01:05:16). Let me see. Man, I don't -. 13 That, as an attachment. I don't have that as 14 an attachment. I do -. I am able to look at 15 other things. But a court list. I don't have 16 that as a court list. I don't have the court 17 list. 18 MR. : Now, you're talking about 19 electronically, or are you referring to -- 20 MS. : Mm-hmm. 21 MR. : -- okay. 22 MS. : Yeah. Because I saw - there 23 were things that I saved. That's how I was 24 able to send them, you know, to other 25 individuals. Meaning, in the agency. When EFTA00127270 LIMITED OFFICIAL USE 67 1 there was a request. But that, I don't see, 2 for whatever reason. I don't see that file. I 3 mean, I don't see that. 4 MR. : Now, it sounds like this 5 specifically was, they were documents that you 6 obtained physically. 7 MS. : Mm-hmm. 8 MR. : Do you know, do you still 9 have any of those documents? When you say you 10 kept the file -- 11 MS. : No. 12 MR. : -- are they hard copy -- 13 MS. : No. 14 MR. : -- files? 15 MS. : No. It's not a hard copy file. 16 Any hard copy files, they were turned over. 17 Items that I have were turned over. And then, 18 there was some things that were still in my 19 possession. I have the emails where it shows 20 who it is that I turned them over. It was 21 myself and Lieutenant that was actually 22 working together. She was assigned to SIS. 23 Working together to gather the documents. And 24 then, there was some documents that were turned 25 over to the FBI. And that could, in fact, have EFTA00127271 LIMITED OFFICIAL USE 68 1 been one of the documents that was turned over 2 to the FBI. There should be a list of what was 3 turned over to them. 4 MR. : Okay. And do you know if 5 it was the FBI versus the OIG? 6 MS. : No. 7 MR. : You don't know who it 8 was? 9 MS. : I don't know because I - like I 10 said - any documents that Lieutenant 11 would have turned over, it should have been 12 There should be something, some kind of 13 document indicating what was turned over to 14 them. 15 MR. : And do you know -. So, 16 there should be some kind of a receipt with the 17 documents -- 18 MS. : There should be. 19 MR. : -- that were provided? 20 MS. : Yeah. Mm-hmm. 21 MR. : And that would be 22 something that Lieutenant would have? 23 MS. : If she, in fact, turned those 24 documents over, she worked in SIS. 25 MR. : Okay. So, it wouldn't -. EFTA00127272 LIMITED OFFICIAL USE 1 You didn't turn it over to the FBI. She -- 2 MS. : No. Yeah. I didn't have any 3 contact with the FBI agents directly. At all. 4 MR. : Okay. And then, as far 5 as - what is your understanding of what it 6 means, though, when it says, "Court 7 documentation regarding WAB." Do you know what 8 court -- 9 MS. : That was -- 10 MR. : -- documentation you 11 would be referring to? 12 MS. that was (Indiscernible 13 *01:08:04). I don't know specifically, but 14 obviously, it would have to have been something 15 that said for, in order for me to write WAB, 16 without being able to look at it right now, it 17 obviously had to be something that said WAB on 18 it, and listed that inmate's name. Other than 19 that, I would not have wrote that. 20 MR. : And do you think that 21 that would have been that Receiving and 22 Discharge document that the SHU staff would 23 have utilized when they transported Reyes to 24 R&D? 25 MS. : It wouldn't have been his - EFTA00127273 LIMITED OFFICIAL USE 70 1 that document from SHU. Because I didn't even, 2 I didn't go to SHU that day. So -- 3 MR. : Sorry. But -- 4 MS. (Indiscernible *01:08:42). 5 MR. : -- the court production 6 list that, I'm just saying that, because my 7 understanding is, R&D, you know, prints out all 8 the same court production lists, and they 9 provide it to the different housing units, and 10 to the ops lieutenant, and to, you know, the 11 different various people that need to be in the 12 know with who is being produced. So, that is 13 all -- 14 MS. : Mm-hmm. 15 MR. : -- all I'm saying, is, 16 like -- 17 MS. : Uh-huh. 18 MR. : -- would it be the -- 19 MS. : A copy of it. You're saying a 20 copy. It could have -. It had to be a copy of 21 something. But I don't know if it was, if it 22 was the court production list, or some kind of 23 Sentry roster. That, because you could print a 24 Sentry roster also, that shows, like you said, 25 everybody, you know, movement. So, it had to EFTA00127274 LIMITED OFFICIAL USE 71 1 be a copy of something listing information as 2 to who was going out of the institution on that 3 particular day. 4 MR. : Okay. 5 MS. : That is the only thing I could 6 have - that I could surmise why I would have 7 wrote WAB. 8 MR. : Okay. Can I ask you just 9 to see if, you know, after the interview, if 10 you can, if you can track that down by any 11 means? Or if you may -. I don't know if you 12 can coordinate with Lieutenant - can ask 13 Lieutenant , as well - but if you could 14 just see if you, in fact, did make a copy, or 15 you know what you did with this document, or 16 figure out what that document was. And I don't 17 know how you would do that. So, I don't, you 18 know -- 19 MS. : Yeah. 20 MR. : -- you might not be able 21 to, but just, if you could just check. 22 MS. : Mm-hmm. That means all of 23 them, the documents that I listed, those things 24 were turned over. But okay. I will even look 25 at all of my emails I saved. Well, what I - EFTA00127275 LIMITED OFFICIAL USE 1 whom I turned things over to, or what I've 2 turned, what I turned over. 3 MR. : That would be great. 4 Specifically, we would be very interested in 5 that court documentation regarding, you know, 6 Reyes. 7 MS. : Mm-hmm. 8 MR. : And is it surprising to 9 you now, though, since again, like, you thought 10 that he was at court, and then released on, you 11 know, released from there, but now that you see 12 that you actually wrote, "Court documentation 13 regarding WAS," is that surprising? 14 MS. : Well, I won't say it's -. I 15 won't use the word "surprising." But it would 16 jog my memory to say, okay, you - like I Said - 17 if he left on WAB, I have something that says 18 WAB, that is what it was. WAB. But did I know 19 at the time, or was I in the know? No. This 20 is after the fact. 21 MR. : Right, right, right. No. 22 I'm just saying the, you know, it seems like a 23 lot of people seemed to think that he was, you 24 know, sent to court and released, whereas, you 25 know, as we just discussed, he was actually EFTA00127276 LIMITED OFFICIAL USE 73 1 transferred. So, I was just wondering if that 2 surprised you to find out that, oh, wow, I 3 actually did know he was WAB after the, you 4 know, on -- 5 MS. : Yeah, well -- 6 MR. : -- August 10th. 7 MS. : -- yeah, that part, because 8 that is, like you said, that has been, that has 9 been the discussion all along, that Reyes went 10 to court, and he was released from court. So, 11 I'm hoping that my information is accurate, but 12 typically, when you - because it's now, it 13 seems like, it conflicts, obviously, with what 14 everyone's recollection is - but typically, 15 when you see WAB, that means With All 16 Belongings, that the person is leaving, they 17 are transferring. Now, how the whole court got 18 into play, maybe, I don't know. And I don't 19 want to speculate, because it is just going to, 20 you know, further confuse everything. 21 MR. : Okay. Yeah. No. I 22 think we've definitely cleared up the fact that 23 he was WAB, and he transferred, just upon the 24 emails that we, you know, I talked to you about 25 with the U.S. Marshals Service, as well as this EFTA00127277 LIMITED OFFICIAL USE 74 1 one. But I was just, you know, for you being 2 that you are the one who gathered that 3 document, I'm just hoping that we can figure 4 out where that document went, because 5 MS. : Sure. 6 MR. : -- you know, it's really 7 the R&D document, and I'm hoping that that's 8 what it is, that we can track down, is whatever 9 they -- 10 MS. : Well -- 11 MR. : -- generated. 12 MS. : I want to clarify. It may 13 not be their specific document. If it's a 14 document that says WAB. 15 MR. : Absolutely. 16 MS. : It doesn't necessarily have to 17 be their, you know -- 18 MR. : No, no. Absolutely. I'm 19 just hoping that it is. And that we can track 20 it down -- 21 MS. : Okay. 22 MR. : -- is what I'm saying. 23 Like, I don't know what it is, because again, 24 it's not -- 25 MS. : Yeah. EFTA00127278 LIMITED OFFICIAL USE 75 1 MR. : -- specific. But yeah, I 2 was just hoping that you would be able to, you 3 know, provide some clarification on that 4 document. 5 MS. : Yeah. 6 MR. : Now, just to back up a 7 little bit. Now, what was your responsibility, 8 like, the AWs are kind of split. Right? 9 There's two AWs, and one is in charge of one 10 thing, and another is in charge of another. 11 What - when you were at the MCC - what were you 12 in charge of on August 9th and 10th? 13 MS. : What? I was in - I had 14 oversight of correctional services. 15 MR. : Okay. So, you actually 16 did have oversight over this incident? 17 MS. : Mm-hmm. 18 MR. : And is that -- 19 MS. : Well -- 20 MR. : -- is that why you would 21 have -- 22 MS. : I think what -- 23 MR. : -- gathered all those 24 documents? 25 MS. : -- not specifically only EFTA00127279 LIMITED OFFICIAL USE 76 1 because of that. But because I just know there 2 is an incident that happened, because I've been 3 an exec staff, and there is certain things that 4 you should gather. But it wasn't because I was 5 the AW of correctional services. Now, as an 6 AW, or someone in exec staff, you should just 7 know kind of what to gather anyway. 8 MR. : Okay. 9 MS. : What information to gather. 10 MR. : Okay. Great. And on 11 that note, would that have been something that 12 you would have gathered, specifically the R&D 13 court production list? 14 MS. : No. Hmm-mm. 15 MR. : No? 16 MS. : No. Mm-hmm. 17 MR. : But it's just something 18 that had -. Something that was court 19 production for Reyes with WAB, you just don't 20 know what it was. 21 MS. : I gathered all of the 22 information that I knew logically was 23 associated with Epstein. 24 MR. : Okay. 25 MS. : That was, it's just logical EFTA00127280 LIMITED OFFICIAL USE 77 1 connections, if you wanted - if you know you 2 have an incident, and you know something 3 happened, in the Special Housing, and there is 4 only two inmates that are in the cell, you know 5 you are not only going to focus on, quote 6 unquote, "The victim." You have to then also 7 turn your attention to who was in the cell at 8 the time. So, to me, anything that I gathered, 9 as far as Sentry information for Epstein, or 10 his Special Housing Unit record, I gathered the 11 same for his cellmate because that's just a 12 logical thing to do. 13 MR. : Sure. And that is what 14 I'm asking for my question. Being that you 15 logically gathered these documents, and you can 16 see that you wrote the document, I'm asking, 17 like, can you recall what would be - what would 18 have been the logical document that you would 19 have gathered, that would have showed that he 20 was -- 21 MS. : Oh, I understand what you mean. 22 MR. : WAB? 23 MS. : Mm-hmm. I don't, I don't know 24 if I would have gone in R&D to see, or if I ran 25 - or if it was a Sentry roster, like, a log, a EFTA00127281 LIMITED OFFICIAL USE 78 1 2 3 4 PP-37 log that showed something. But I don't thinking about it now - I honestly, I can't say that, because I do have other R&D documents, but I don't know if that was that R&D court 5 roster. 6 MR. : If you don't mind, and if 7 it's not too much trouble, can you just send me 8 an email with the documents that you do have, 9 and then I can go through them to figure out 10 what it is we have and don't have, and what we 11 need, and don't need? 12 MS. : Sure. 13 MR. : With regards to this 14 incident. 15 MS. : Okay. 16 MR. : You can just, like, and 17 not right now. After, after we're done. 18 MS. : Okay. Not right now. 19 MR. : Yeah, yeah. 20 MS. : Okay. 21 MR. : No, no, not right now. 22 MS. : Okay. Mm-hmm. 23 MR. : All right. So -- 24 MS. : And I will also look at other 25 emails that I sent out, because it's been, like EFTA00127282 LIMITED OFFICIAL USE 79 1 I said, it's been, it's been several requests 2 to show what I had and what I didn't have. So, 3 any other emails, I will be more than happy to 4 share with you. 5 MR. : Yeah. If you can just, 6 if that's possible, just to forward me those 7 emails that you have provided -- 8 MS. : Mm-hmm. 9 MR. : -- that had documents 10 with regarding, with regard to the matter. 11 MS. : Mm-hmm. 12 MR. : That would be great. So, 13 being that you were the AW in charge of 14 custody, you would probably be perfect to 15 answer some of these questions. So, since 16 Epstein was required to have a cellmate, what 17 should have happened once the notification wa - 18 made that Reyes was being transferred? 19 MS. : He should have received another 20 cellmate. 21 MR. : And obviously, we 22 probably did just cover this, and just because 23 we got sidetracked, and you said that SHU 24 staff, once they found out that Reyes was 25 transferred, they should have notified, EFTA00127283 LIMITED OFFICIAL USE 80 1 Lieutenant wasn't there, so they should 2 have notified either the activities lieutenant, 3 or the operations lieutenant. Is that what you 4 said? 5 MS. : I'm saying that someone of a 6 supervisory nature, yeah, should have been 7 notified. 8 MR. : But who was it that 9 should have notified them? Would it be the OIC 10 of the SHU? Would it be the person that 11 transferred Reyes to R&D? You know it, when I 12 say transferred, I mean escorted him to R&D. 13 Should it have been R&D themselves? Who should 14 have made the notification to the lieutenant? 15 MS. : And without me spinning the 16 tale, and pointing a finger, because lack of, 17 it didn't, it all depends. For instance, if 18 the SHU staff knew that Reyes - and that's why 19 it's just kind of, I don't know, a question 20 mark - if the SHU staff knew that Reyes was not 21 coming back, then that would mean that they 22 would know that he wasn't, he was not going to 23 have a cellmate. So, without knowing what 24 everybody knew, I 25 MR. : Okay. So, I'll -- EFTA00127284 LIMITED OFFICIAL USE 81 1 MS. : -- (Indiscernible *01:17:59) 2 MR. -- fill you in on that. 3 MS. : Right. 4 MR. : So -- 5 MS. : Yeah. 6 MR. . Do you know 7 who Roberto is? 8 MS. : Yes. 9 MR. : So, he was the SHU OIC at 10 the time. He's the one who escorted Epstein to 11 attorney conference that morning. And -- 12 MS. : Mm-hmm. 13 MR. : -- at the same time, they 14 were jointly escorted with, I believe it was 15 Monge, but one of the, one of the SHU, one of 16 the internal staff who provided, produced Reyes 17 to R&D. They both did the -- 18 MS. : Mm-hmm. 19 MR. : -- they both escorted 20 their inmates together. And during their 21 conversation, it was discussed that Reyes was, 22 in fact, WAB, and -- 23 MS. : Okay. 24 MR. : -- would be getting a new 25 cellmate. EFTA00127285 LIMITED OFFICIAL USE 1 MS. : Mm-hmm. 2 MR. : So, knowing that 3 was present, and there was an internal employee 4 that was present, and they both had this 5 discussion, and both said that they -- 6 MS. : Mm-hmm. 7 MR. : -- knew that he was WAB, 8 does that clue you in a little bit more of what 9 10 MS. : Yeah. 11 MR. : -- actions should have 12 taken at that time? 13 MS. : Yes. Either one of them should 14 Now, either one of them. So, you said 15 was was the OIC? 16 MR. -: was the OIC. He 17 was the one that was -- 18 MS. : Okay. 19 MR. : -- bringing Epstein, and 20 the conversation was had with both Epstein and 21 Reyes, saying, Reyes, we know you're leaving, 22 you're WAB. Epstein, you'll get a new cellmate 23 by the end of the day. 24 MS. : Now, as the OIC, 25 should have then contacted the lieutenant. EFTA00127286 LIMITED OFFICIAL USE 83 1 MR. : Okay. So, being the AW 2 in charge of custody, do you believe that 3 MS. : Mm-hmm. 4 MR. : -- it was really 5 that should have made that notification? 6 MS. : Because as the OIC, that means 7 that you are, if you look at the post orders, 8 you are basically have oversight of SHU, for 9 lack of a better term. You should make sure 10 that the rounds are being conducted. If 11 inmates needs to be pulled out for whatever 12 reason. That the appropriate inmates are going 13 in their appropriate cages, so that, you know, 14 separate tees are adhered to. That inmates are 15 being fed. That sanitation is being conducted. 16 And if, and because you are now telling me 17 that this individual, whomever the individual 18 is, is saying that they were aware that Epstein 19 needed a cellmate, and that his cellmate was 20 leaving, they knew, so when you know something, 21 then you should, either you're going to - if 22 you didn't want to make the determination to 23 make another decision about who the cellmate 24 would be, then you need to contact your 25 supervisor. EFTA00127287 LIMITED OFFICIAL USE 84 1 If you, yourself, can't make a decision, 2 you contact your supervisor who is authorized 3 to make that decision. But you must make the 4 contact in order for your supervisor to know. 5 And as an OIC, you are aware of who you can 6 contact. 7 MR. : Yeah. 8 MS. : That's plainly known that you 9 can contact the lieutenant when something is 10 going on, especially for something that, it's 11 not, it's the Special Housing Unit, that you 12 must be able to get a decision maker. 13 MR. : Okay. So, he should have 14 notified a lieutenant, is basically the long 15 and short of it? 16 MS. : Yes. Yes. The long and short 17 of it, he should have notified a lieutenant. 18 MR. : Okay. And are you aware 19 if - we are going to just touch on counts and 20 rounds that were conducted in the SHU - are you 21 aware if the SHU counts and rounds were not 22 conducted by the SHU staff on August 9th and 23 10th of 2019? 24 MS. : I was aware after the fact that 25 the staff members indicated that they did not EFTA00127288 LIMITED OFFICIAL USE 1 make rounds. 2 MR. : And what did you become 3 aware of? Can you just give me a little bit 4 more clarity on that? 5 MS. : Well, I became aware of it just 6 like everybody else, you know, that the staff 7 members are saying that they didn't make 8 rounds. But was I aware of it on the day? No. 9 MR. : No, no, no. I'm sorry -- 10 MS. (Indiscernible *01:21:57). 11 MR. : -- so, what I mean is, 12 like, what did you became aware of? What staff 13 members, and what did you learn? 14 MS. : Oh. Oh, oh. Okay. The two 15 staff members that were assigned on the morning 16 watch shift, that they have said that they did 17 not make rounds. 18 MR. : And is that and 19 20 MS. : Yes. Those were the two staff 21 members that worked that shift. 22 MR. : And do you remember who 23 you learned that information from? 24 MS. : No. Hmm-mm. 25 MR. : Okay. Did either EFTA00127289 LIMITED OFFICIAL USE 86 1 or say that that, you know, tell you that 2 information directly? 3 MS. : No. I didn't I haven't 4 even, from the day of the incident, I have not 5 laid eyes on either one of them. 6 MR. : Okay. 7 MS. : Besides on TV. So, I have not 8 spoken to either one of them. Well, no, and 9 I'm not going to say I haven't spoken to either 10 one of them. I did call to make welfare checks 11 on staff members, to see if they were okay, and 12 that was weeks after, because they haven't been 13 at work, and that's what we were told to do, to 14 call the staff members, just to say, you know, 15 if you're okay. Because they physically were 16 not in the institution. But as far as 17 discussing the incident, and what they did and 18 did not do, I did not engage in that. 19 MR. : Okay. And did you learn 20 anything, you know, during your time on this, 21 did you learn anything about the accuracy of 22 the MCC SHU counts and rounds on August 9th and 23 10th of 2019? 24 MS. : You said did I run anything as 25 far as the -. EFTA00127290 LIMITED OFFICIAL USE 87 1 MR. : Did you learn if they 2 were accurate or not? Like, the counts that 3 they conducted, and the rounds they conducted. 4 Did you find out through your, you know, what 5 you were doing, did you learn if they were 6 accurate counts and accurate rounds? 7 MS. : The date, the date, you're 8 saying the date of when I was gathering the 9 information, or the documentation? 10 MR. : Or at any point. Did you 11 ever find out if the counts were either 12 accurate or not? And the rounds were accurate 13 or not. 14 MS. : Not specifically about the 15 counts and the rounds, but just like, like I 16 said, and like everybody else, of what has come 17 out, that they said that they did not do 18 counts. I mean, do rounds. 19 MR. : But had you heard 20 anything about, like, the counts being wrong? 21 Like, they're actually reporting the wrong 22 numbers, or anything like that? 23 MS. : In the SHU. I'm trying to 24 remember. I know that there was, there was 25 discussion about whether or not the count was EFTA00127291 LIMITED OFFICIAL USE 88 1 done because, and I can't remember exactly what 2 happened to make that come up, but I know there 3 - we couldn't find certain count slips. And I 4 think somebody, and I can't remember if it was 5 Epstein, or Reyes, or somebody was not keyed 6 out. One of the inmates was not keyed out, and 7 if that, and my memory is serving me properly, 8 and the count should have been affected by -- 9 MR. : Right. And did -- 10 MS. : -- you know, inaccurate Sentry. 11 Inaccurate Sentry information. 12 MR. : -- okay. So, you are 13 aware of that then. Yeah. So, do you know, 14 it's, I think the inmate's name was Fernandes. 15 Does that ring a bell? Someone that 16 MS. : I -- 17 MR. : -- was found to have 18 been, passed contraband, and then, they were 19 removed from the SHU and placed in R&D holding 20 cell, but they were not actually keyed out of 21 the SHU? 22 MS. : No. I don't - hmm-mm - I don't 23 remember that specific. Hmm-mm. 24 MR. : Okay. But you remember 25 someone wasn't keyed out, which messed up the EFTA00127292 LIMITED OFFICIAL USE 1 counts? 2 MS. : If you, it was something to 3 that effect. That there was somebody not keyed 4 out. I don't know if it was about SHU or about 5 the institution itself. But I know that there 6 was something about, there was some Sentry 7 inaccuracies that should have affected the 8 count. 9 MR. : Okay. And do you know if 10 that was documented anywhere, or you, you know, 11 provided information to anyone on that, that 12 you might be able to retrieve, to help, you 13 know, help us? 14 MS. : I'm going to try. 15 MR. : You know, you don't have 16 to do it now. 17 MS. : Yeah. 18 MR. : But this is another one 19 of those -- 20 MS. : Okay. 21 MR. : -- things that if -- 22 MS. : All right. 23 MR. : -- you can put that to 24 your -- 25 MS. : Let me do Fernandes. EFTA00127293 LIMITED OFFICIAL USE 1 MR. : -- yeah. 2 MS. : Okay. 3 MR. : Yeah. So -- 4 MS. : Yeah. 5 MR. : -- if you can -- 6 MS. : Mm-hmm. 7 MR. : -- those two things. 8 One, whatever documents -- 9 MS. : What's his -? 10 MR. : -- (Indiscernible 11 *01:25:53). 12 MS. : What is Fernandes's register 13 number? 14 MR. : Let me pull that up. 15 That wasn't something I was going to touch on 16 with you, but since you brought it up, that's 17 the only reason I did. Let's see. All right. 18 And this one, I just have inmate Fernandes. 19 Let me -. Hold on. All right. So, it's 20 Leonardo. L-E-O-N-A-R-D-O. 21 MS. : Mm-hmm. 22 MR. : Fernandes. F-E-R-N-A-N- 23 D-E-S. 24 MS. : Mm-hmm. 25 MR. : Register number- EFTA00127294 LIMITED OFFICIAL USE 1 2 MS. : Okay. And you said he was -. 3 MR. : And there is, you 4 actually have an -. Actually, what I pulled up 5 was an email from to both you 6 and So, and it talks 7 MS. : And it said, it talks about 8 that? 9 MR. : No. It talks about the 10 incident, where it just talks about, the date 11 was Friday, August 9th, 2019, at 3:52 p.m., and 12 it just says, "On August 9th, 2019, at 13 approximately 1:37 p.m., while conducting 14 routine duties, the 9 South visiting officer 15 observed a female visitor produce an unknown 16 object from her waistband and hand it to inmate 17 Fernandez." And then, it just talks about, you 18 know, a little bit more of it. But this is the 19 individual -- 20 MS. : Okay. 21 MR. : -- that was not keyed out 22 of the SHU. And he was placed in R&D -- 23 MS. : Okay. 24 MR. : -- the R&D holding cell, 25 which caused the count numbers to be EFTA00127295 LIMITED OFFICIAL USE 92 1 inaccurately reported. Because the SHU staff 2 was still adding him on their count slips. 3 MS. : Yeah. Mm-hmm. Okay. Okay. 4 MR. : And does that -- 5 MS. : Okay. 6 MR. : -- does that -- 7 MS. : Okay. 8 MR. : -- does that refresh your 9 memory at all? 10 MS. : Hmm-mm. But you're saying, so, 11 but email doesn't talk about that. It 12 just talks about -- 13 MR. : No, no, no. 14 MS. : -- (Indiscernible *01:28:02). 15 MR. : It just talks about the 16 incident. 17 MS. : Okay. 18 MR. : It doesn't -- 19 MS. : Okay. 20 MR. : -- it doesn't talk about 21 the fact that it -. That's something that our 22 investigation has revealed. 23 MS. : Oh, okay. 24 MR. : Because we had to figure 25 out why are, you know, are the counts accurate EFTA00127296 LIMITED OFFICIAL USE 1 or not, how do we find out if they -- 2 MS. : Mm-hmm. 3 MR. : -- actually conducted the 4 counts, or didn't conduct the counts. 5 MS. : Okay. 6 MR. : So, when we went through 7 everything, we found that there was some 8 discrepancies based upon what was on the 9 lieutenant's log versus what was on 10 institutional count, which was on the, you 11 know, count slips. There are different things. 12 And then, you know, looking through the 13 lieutenants log, we see that, on August 10th, 14 during the night, at around 12:30 a.m., it has 15 a note in there, saying that they keyed 16 Fernandez out of the SHU, or out of the SHU, 17 and into wherever, R&D. And that's how we were 18 able to figure out, okay, these count slips are 19 actually all off. 20 MS. : Oh. 21 MR. : They are saying that they 22 were counting this many bodies, whereas, in 23 fact, there was one less because he wasn't 24 there. 25 MS. : Okay. Yeah. That doesn't jog, EFTA00127297 LIMITED OFFICIAL USE 94 1 that doesn't jog my memory for that, though. 2 MR. : Okay. 3 MS. : Yeah. 4 MR. : This is kind of the first 5 you're hearing of that, then? 6 MS. : Yeah. I don't, I don't -. If 7 for whatever reason, this is, I don't recall 8 anything about that. 9 MR. : There was something you 10 recalled about the counts being off, but it 11 wasn't that? 12 MS. : Yeah. But it wasn't that. 13 Hmm-mm. 14 MR. : But you did know that 15 someone wasn't keyed out? 16 MS. : I, perhaps out of the 17 institution, and again, if something came up 18 about the count, but I don't recall there being 19 - and because it's -- 20 MR. : Well, I think -- 21 MS. : -- (Indiscernible *01:29:35) 22 MR. : -- well, there was a 23 question that - and maybe this is something 24 that the warden asked you - but Ray Ormond, who 25 I'm assuming you know - correct? - the regional EFTA00127298 LIMITED OFFICIAL USE 1 director at the time. 2 MS. : Yeah. Mm-hmm. 3 MR. : He sent an email to 4 Warden , on the, I believe the 10th, 5 asking, "Why are the counts off? Why does one 6 say 72, and one say 73?" Maybe. 7 MS. : For Special Housing? 8 MR. : For Special Housing. 9 Correct. So, maybe -- 10 MS. : Mm-hmm. 11 MR. : -- that's where they 12 asked you. Do you recall? 13 MS. : And you said, when did, that 14 happened on the day of 8/10? 15 MS. : Yeah. That would have been 16 Ray, Mr. Ormond asking on 8/10 because 17 18 MS. : Mm-hmm. 19 MR. : -- he was provided all 20 the count documentation, and asking him -- 21 MS. : Mm-hmm. 22 MR. : -- why are these counts - 23 ? Why did the count - oh, no. He said, "Why 24 did the count change?" That's what it was. 25 MS. : Okay. EFTA00127299 LIMITED OFFICIAL USE 96 1 MR. : He was, like, from the 2 10:00 p.m. 3 MS. : That's probably -- 4 MR. : -- count to midnight, it 5 changed from 73 down to 72, and our 6 investigation has revealed it's because this 7 person was never keyed out of the SHU -- 8 MS. : Mm-hmm. 9 MR. : -- until -- 10 MS. : That is maybe that is what 11 prompted it, but like I said, I knew something 12 happened with the count, and from that, I - 13 myself and Lieutenant were trying to 14 gather the count slips, and it should be a 30- 15 day file maintained in control, and we were not 16 able to find the count slips. So, I didn't 17 know it. Well, now that you're telling me, I 18 didn't know it was because of that. And there 19 is some things that I was in the know about, 20 that I - or I wasn't - but I knew it had 21 something to do, like, is that with the counts, 22 and we were told to get some of the count 23 slips. 24 MR. : Okay. But just, you 25 don't have anything to add to that. This is EFTA00127300 LIMITED OFFICIAL USE 1 all kind of -- 2 MS. : Mm-hmm. 3 MR. : -- more new information 4 for you? 5 MS. : Yes. Mm-hmm. 6 MR. : Okay. We can move on, 7 then. 8 MS. : Okay. 9 MR. : What is a lieutenant - or 10 sorry - a SHU lieutenant round? So, sorry. 11 So, when a lieutenant conducts a round in the 12 SHU, what should that consist of? 13 MS. : So, when you're the SHU 14 lieutenant, you -- 15 MR. : And I don't mean 16 specifically the SHU lieutenant. I said that 17 wrong. 18 MS. : Okay. 19 MR. : In the first. 20 MS. : Okay. 21 MR. : Just when a lieutenant, 22 whether it's an activities, a SHU lieutenant -- 23 MS. : Okay. 24 MR. : -- an activities 25 lieutenant, an operation lieutenant. When EFTA00127301 LIMITED OFFICIAL USE 1 lieutenant goes to the SHU and conducts a 2 round, what should they be doing when they 3 conduct a round? 4 MS. : They should be walking around 5 and talking to the inmates. 6 MR. : So, is there, is the SHU 7 Is a lieutenant round the same thing as a 8 staff round, where you are supposed to go up 9 and actually check on the inmates? 10 MS. : Hmm. I'm not going to say it's 11 the exact same thing because the staff in SHU, 12 they actually have to record that they have 13 done rounds. And by them recording that, they 14 are indicating that they recorded timely 15 rounds, and that they actually are able to say 16 with certainty that they looked, you know, that 17 they verified that all the inmates are there, 18 and that they are alive. Versus a lieutenant, 19 what your responsibility is, you are just 20 making, you are generally making sure that you 21 go around and ensure that everything is okay. 22 But are you specifically and stopping at every 23 single cell? I wouldn't say necessarily that 24 that is exactly, but it mimics the same 25 requirement as the staff. EFTA00127302 LIMITED OFFICIAL USE 1 MR. : Okay. So, if Reyes is 2 gone at 8:30, approximately 8:30 a.m. on August 3 9th -- 4 MS. : Mm-hmm. 5 MR. : -- and there is 6 obviously, I think there is supposed to be at 7 least, what? One lieutenant round conducted in 8 the SHU per shift? 9 MS. : Mm-hmm. 10 MR. : Is that -- 11 MS. : Mm-hmm. 12 MR. : -- is that correct? 13 MS. : Mm-hmm. 14 MR. : So, if there is an 15 activity, you know, the SHU lieutenant is out, 16 so there is an activities or an ops lieutenant 17 conducting a round, both the day shift and the 18 night shift, and then, the operations 19 lieutenant conducting one in the morning shift. 20 Should any of those lieutenants realized, when 21 they were doing their rounds, that Epstein, you 22 know, Reyes was gone, and/or Epstein was by 23 himself? 24 MS. : Yeah. If - now, that's a -. I 25 would say yes. I would say yes. EFTA00127303 LIMITED OFFICIAL USE 100 1 MR. : And how should have they 2 known that? What should have the -. What 3 should have clued them in on the fact that 4 Reyes is gone, and Epstein is by himself? Or 5 if Epstein is in attorney conference, there is 6 just no one in the cell in general. 7 MS. : Well -- 8 MR. : Since they have names on 9 the door tags, like you said. 10 MS. : -- that's what I was going to - 11 yeah - that's what I was going to say. But the 12 names on the -. The names on the door tag. 13 When someone leaves, you should remove the door 14 tags, so then, in fact, there should have only 15 just been one tag on the door. You wouldn't 16 have, you wouldn't have two tags on the door if 17 there is only supposed to be one person in 18 there. So, the tag should have been removed. 19 And -. 20 MR. : Do you know if the tag 21 was removed for Reyes? 22 MS. : That, I don't know if Reyes' 23 tag was removed, because I didn't go in the 24 Special Housing Unit. So, I don't know if his 25 tag was removed. But you - by us talking - you EFTA00127304 LIMITED OFFICIAL USE 101 1 indicated that the SHU staff was aware that he 2 was leaving. So, they put the tags up, they 3 should remove the tags. And there would be no 4 reason to keep a tag on the door, indicating 5 that there is two inmates. One, when you are 6 aware that he is no longer going to be there. 7 MR. : But should 8 MS. : Yeah. 9 MR. : -- should those 10 lieutenants have conducted a round on basically 11 Epstein's cell? 12 MS. : I would -. You would conduct a 13 I would say yes. Because especially if you 14 have a highlighted inmate, or an inmate of 15 great concern. Or someone that you know you 16 need to check on. If you are not going to look 17 at anybody else's cell, you would definitely 18 look at, or check on, the inmates that are of 19 concern, to even say, hey, you okay? Or, you 20 know, just to talk with them, or physically see 21 them. So, I would say that you would - yeah - 22 that you would have looked in his cell to see 23 something, that something is going on. 24 MR. : Now, what about -- 25 MS. : And then -. EFTA00127305 LIMITED OFFICIAL USE 102 1 MR. if Epstein -. So, if 2 they are conducting their rounds when Epstein 3 is in attorney visits, should they still be 4 checking in on his cell itself, like, to make 5 sure everything is okay with his cellmate, or 6 anything like that? 7 MS. : Well, if he was, if he was 8 physically inside of his, he physically was not 9 inside the cell at the time, but the only way 10 for you to know, because why would the 11 lieutenant automatically know that he's in 12 attorney conference? So, you still would have 13 looked in his cell. 14 MR. : So, they - regardless, in 15 this specific, you know, Epstein is your 16 highest profile inmate at the time -- 17 MS. : Mm-hmm. 18 MR. : -- any time a lieutenant 19 basically goes into that SHU, they should 20 really check on him? And check on that cell? 21 MS. : I would say so. 22 MR. : Okay. But that is more 23 of a, you know, it sounds like it's not 24 necessarily a policy, but just, that's good 25 practice. Is that what you are saying? EFTA00127306 LIMITED OFFICIAL USE 103 1 MS. : Yeah. Yeah. That's what I'm 2 saying. And because it was known, as you and I 3 discussed, that he should have a cellmate. So, 4 there's certain things that you would be 5 checking for, you would be checking for his 6 welfare, and you would also be checking to make 7 sure that those recommendations were adhered to 8 because you want to make sure, with certainty, 9 if you are saying that you made the round, you 10 are annotating it in the book that you made the 11 round. And you would want to say that you 12 actually went around to them, and you checked 13 on these things. 14 MR. : But is there any kind of 15 BOP or MCC policy or directive that, you know, 16 they would have violated, if they didn't in 17 fact check on Epstein's cell? 18 MS. : I can't say that it would be a 19 I don't know about the lieutenant, that 20 they would say that, because they didn't look 21 in one cell or two cells. But I do know, if 22 you are indicating, and then, that's another 23 thing. If you are, when you come inside of the 24 Special Housing Unit, there is a logbook. If 25 you are annotating in the logbook that you are EFTA00127307 LIMITED OFFICIAL USE 104 1 visiting, or if you are indicating in the 2 logbook that you are doing a round, you -. So, 3 I'm going to backtrack what I said before. 4 MR. : Well, there is an actual 5 log sheet that they sign. So, the lieutenants 6 actually have to sign that they conducted their 7 round. 8 MS. : So then, that's why I'm going 9 to backtrack then. If you are saying that you 10 did rounds, that means that you should have 11 looked in all of the cells. 12 MR. : Okay. And so, for a 13 lieutenant, that - and that, so, this is where 14 we've been getting kind of different 15 information - some lieutenants are saying, 16 absolutely, you need to go down each range, 17 check on every cell door. Other lieutenants 18 are saying, no, no, no, no, we're just supposed 19 to check in with the staff member that are in 20 there, and make sure that they don't have any 21 problems. Our rounds are really conducted on 22 the staff members, not on the inmates. So, 23 that is where I am - and there is nothing that 24 I can find, specifically in policy, that really 25 specifies that information. EFTA00127308 LIMITED OFFICIAL USE 105 1 MS. : Yeah. So, I - and that's where 2 I was kind of weaving back and forth. A 3 lieutenants' purpose, let's just say in the 4 general housing, like, general, you know, GP. 5 You are making rounds on the unit, you're 6 checking on, generally, you're checking on the 7 unit itself. And you don't, you would not go 8 down, and checking every cell, because that's 9 general population. You don't anticipate being 10 in SHU. And you are making yourself available 11 in the event that the staff member needs 12 something. So, you are physically supposed to 13 go. But if it's the Special Housing Unit, and 14 then, also 10 South, which MCC also has. 15 MR. : Correct. 16 MS. : Your responsibility level, 17 because of the practices, or just you knowing, 18 inherently, what you should be doing, it's a 19 little different than the just making yourself 20 available to the staff. You are not just there 21 for the staff. You are also there for the 22 inmates because they can't come to you. You 23 have to go to them. 24 MR. : Okay. So -- 25 MS. : So -. EFTA00127309 LIMITED OFFICIAL USE 106 1 MR. : -- so, basically, I'm 2 understanding that general population, no, a 3 SHU - or a lieutenant wouldn't have to - with 4 their rounds - don't have to be with the 5 specific inmates, but in the SHU, because they 6 have limited movement, and they are only in 7 their cells, a lieutenant really should be 8 checking on each cell, during their rounds? 9 MS. : For - like you said - for good 10 correctional judgment, sound correctional 11 practices, you - yeah - you would. 12 MR. : But to your knowledge, 13 there is no requirement? It's just sound 14 judgment and sound practice? 15 MS. : Yeah. And because that, but 16 that's why I was going back, because I don't 17 think there is anything written that says when 18 a lieutenant makes his rounds, they should go 19 to every single cell. I know their requirement 20 is, like you said, for you to, for a lieutenant 21 to be present, and to, on every shift, as well 22 as if there is also, also different departments 23 that are required to make rounds. Weekly. And 24 with that in mind, you typically know that that 25 means that you are stopping at every door, and EFTA00127310 LIMITED OFFICIAL USE 107 1 you are talking to the inmates, because again, 2 your purpose in SHU is to provide information, 3 and again, it's not like they can come out to 4 you. So, you have to go to them. 5 MR. : So, just to wrap this 6 thing up, if a lieutenant is saying that they 7 did not conduct any rounds of cells, they just 8 stopped in and talked to staff members. Do you 9 believe that they did something wrong? 10 MS. : I would say that I don't think 11 that they acted responsibly. I don't want to 12 say it's wrong or right because, you know, then 13 that person could say this, it's not written, 14 but I would say that that's not a responsible 15 decision. 16 MR. : So, when they certify 17 their round sheets that they conducted a round, 18 what do you believe that they are certifying? 19 MS. : That they have visited SHU, and 20 that they visited the inmates. 21 MR. : Okay. So, you do believe 22 that certification that they are signing, that 23 they conducted a round in the SHU, is that they 24 actually did conduct a round with the inmates? 25 MS. : That is what I believe. EFTA00127311 LIMITED OFFICIAL USE 108 1 MR. : Okay. But that is more 2 of a belief and opinion versus a knowledge. 3 Correct? 4 MS. : Yes. 5 MR. : Okay. Great. We can 6 move on. Next thing we are going to talk 7 about, and I apologize this has taken a little 8 long, is the cameras. Do you know if the SHU 9 cameras were recording on August 9th and 10th 10 of 2019? 11 MS. : I know there was some -. And 12 again, this is information that has become 13 available after the fact. I know it has become 14 known after the fact that there was some 15 cameras that were not working. And that were 16 not recorded. But did I know the day of the 17 incident? No. I did not know on the day of 18 the incident. 19 MR. : Did you know why they 20 weren't recording? Do you know what happened 21 with the cameras? 22 MS. : I know that, I don't know why 23 they were not working on that day, but I know 24 that, following Epstein, that there have been 25 issues with MCC's cameras. The recorder, that EFTA00127312 LIMITED OFFICIAL USE 109 1 there was supposed to be a backup camera, and 2 that, when the primary camera failed to record, 3 that there was supposed to be another camera 4 that kind of acts, or kind of, you know, 5 interfaces, so that there is always some 6 recording going on. That has been going on, 7 and again, that was after the fact, but as far 8 as the day of, I don't know. 9 MR. : So, you don't know what 10 caused the cameras to stop recording? 11 MS. : No. I don't know. 12 MR. : Okay. And do you 13 remember the - so, on August 8th, which would 14 have been a Thursday - do you remember, if on 15 August 8th, if you and SIS Lieutenant 16 were attempting to review video footage, and 17 you learned that you were not able to rewind 18 the cameras, and review the footage that you 19 were looking for? 20 MS. : You said on August 8th? 21 MR. : Right. And to help 22 further jog your memory. So, the information 23 we received from Lieutenant was that the 24 two of you were attempting to review video 25 footage, you weren't able to, so you called the EFTA00127313 LIMITED OFFICIAL USE 110 1 comtech, Hughwon and asked him to 2 review the matter, and fix the issue. Does 3 that ring a bell to you? 4 MS. : If she's saying that that's 5 happened, and I know, Lieutenant and I 6 have had conversations, and about that, I would 7 say that that's - that if she is saying that 8 she and I had a conversation, I would say that 9 that probably did occur. 10 MR. : But you don't recall it? 11 MS. : I don't know if it was August 12 8th, or if it happened prior to. But I do 13 recall. I, again, I recall her and I trying to 14 look at something, but I don't recall the date 15 or the timeframe. 16 MR. : So, I guess, when you 17 arrived on the 10th, and learned that the 18 cameras weren't recording, which is, I'm 19 assuming, you would have learned on that day, 20 the 10th, that Epstein was found. Is that -- 21 MS. : Mm-hmm. 22 MR. : -- is that accurate? 23 MS. : No. No. That is not accurate. 24 MR. : Okay. When did you learn 25 that the cameras actually weren't, or didn't EFTA00127314 LIMITED OFFICIAL USE 1 record, or weren't recording? 2 MS. : I don't recall exactly when I 3 learned that -- 4 MR. : Oh, okay. 5 MS. : -- but mm-hmm. 6 MR. : Okay. So, when we spoke 7 with Lieutenant , she said, when she 8 found out on the 10th that the cameras weren't 9 recording, she went to and said, hey, 10 what happened? You were to supposed fix this. 11 So, I didn't know if you 12 MS. : Oh. 13 MR. : -- you would have, you 14 know, had a similar reaction, or a similar take 15 on the matter. 16 MS. : Mm-hmm. And she is saying that 17 it was the SHU cameras that were not recording? 18 That -- 19 MR. : Well, she -- 20 MS. (Indiscernible *01:45:44). 21 MR. : -- well, she just said 22 that she knows that there were problems with 23 the cameras. I would have to look back at her 24 transcript to find out exactly if we were 25 talking about the SHU, but she says that -- EFTA00127315 LIMITED OFFICIAL USE 1 MS. : Mm-hmm. 2 MR. : -- the two of you were 3 trying, were attempting to review video, and 4 you were unable to review it because there was, 5 you couldn't find the recording, or you 6 couldn't rewind. So, the, you know, the 7 determination was made between the two of you, 8 and I can actually, let me pull up the actual 9 specific part of what she, of what she said 10 here. To see if you think it's accurate. So, 11 it says, "I remember stepping into his office." 12 Oh, okay. 13 So, "I remember stepping into his office, 14 which was right next door to mine, and 15 notifying him that the camera was down, and I'm 16 trying to get back to look at footage, and I 17 can't. Actually, I had one of the associate 18 wardens with me, as well, who happens to be his 19 supervisor." "So," I said, "Who was that?" 20 "Associate Warden ." " was there?" 21 "Yes." "Okay." "It was me and her together, 22 looking at the camera." 23 "Okay. So, it wasn't ? It 24 was actually ?" "No. It was me and AW 25 • " "And that was with Captain ?" EFTA00127316 LIMITED OFFICIAL USE 113 1 "Yes." "Okay. So then, the two of them knew 2 that the cameras were down?" "Yes." "All 3 right. And do you know if they had any 4 conversation with about a need to get 5 them back up?" 6 She says, "I don't know if they had a 7 separate conversation, but when I called Mr. 8 over the radio, Ms. was still 9 standing there with me in the office, and she 10 was there with me when he came up to check, 11 because we thought it was something that maybe 12 he could just go in, and it allow us to go to 13 look at the camera, and look for what we were 14 looking for." So, does that ring a bell to you 15 at all? 16 MS. : Yeah. That does. Mm-hmm. 17 MR. : Does that sound accurate? 18 MS. : It does. Mm-hmm. 19 MR. : Okay. So, and this was 20 what she was saying, was on August 8th, that 21 she went in. So, do you know if, were you 22 there and present when was brought into 23 the office and told to fix the issue? 24 MS. : I don't recall. I don't recall 25 - hmm-mm - I don't recall having that EFTA00127317 LIMITED OFFICIAL USE 114 1 conversation. And then, and I could have had 2 that conversation, but I don't recall having a 3 conversation with 4 MR. : Okay. So, you don't 5 recall But you do recall 6 MS. : Mm-hmm. 7 MR. : -- this interaction -- 8 MS. : I remember -- 9 MR. : -- with both you, 10 Lieutenant , and -- 11 MS. : Yeah. 12 MR. : -- Captain 13 MS. : Mm-hmm. I do remember that. 14 And speaking of, I don't remember if it was, if 15 it was, because I'm trying to understand if it 16 was because you were saying we just couldn't 17 rewind, or if it was known that it was not, or 18 if it was that the cameras were not recording. 19 I'm hoping that you understand what I'm saying. 20 MR. : Yeah. So, the way that - 21 all right - the question was asked, so I said, 22 "Okay. So then, the two of them knew the 23 cameras were down?" She said, "Yes." And I 24 said, "Oh, all right. And do you know if they 25 had any conversations with about a need EFTA00127318 LIMITED OFFICIAL USE 115 1 to get them back up?" She said, "I don't know 2 if they had a separate conversation, but when I 3 called Mr. over to radio, Ms. was 4 still standing there with me in the office, and 5 she was there with me when he came up to check 6 because we thought it was something that may be 7 he could just go in and it allow us to go to 8 the camera, and look for what we were looking 9 for." 10 I then said, "And when he mentioned the 11 whole -". So then, we started talking about 12 overtime, and when he could fix it, I said, 13 "And when he mentioned the whole, I'll stay 14 overtime, was she there when - was there - 15 when he mentioned that he would stay to work 16 overtime?" And she said, "I can't remember." 17 MS. : Well, and I know that, if I had 18 a conversation with , or anybody, about 19 the cameras not recording, versus you not being 20 able to rewind on your, on the Nice Vision. 21 That that would have been something that would, 22 that I would have known that was important. 23 And I'm trying to differentiate because there 24 are there, and I have had the experience that I 25 have access to Nice. And I was not able to EFTA00127319 LIMITED OFFICIAL USE 116 1 actually rewind on one of the cameras. 2 But it's not because the camera was not 3 recording. It's because it was, the camera was 4 not programmed correctly or something. I don't 5 even know if I'm using the proper word. But 6 it's not that the camera was not recording. It 7 had something to do more with you're not being 8 able to pull it up and rewind it on the Nice 9 Vision application. But it's not the same as 10 it not being recorded. So, that's why I was 11 asking you, is she saying that we knew that it 12 was not recording? Because that's not my 13 knowledge, or my understanding, that the 14 cameras were not recording. 15 MR. : Okay. Yeah. No. Her 16 specific words were, "I remember stepping into 17 his office, which was right next door to mine, 18 and notifying him that the camera was down. 19 And I'm trying to go back and look at the 20 footage, and I can't. Actually, I had one of 21 the associate wardens with me 22 MS. : Yeah. 23 MR. : -- as well." 24 MS. : That - I wouldn't say that that 25 means that the camera is not recording. Hmm- EFTA00127320 LIMITED OFFICIAL USE 1 mm. 2 MR. : So -- 3 MS. : And that -. 4 MR. : -- so, saying the camera 5 was down, that would, what would you think that 6 that was saying? 7 MS. : And that's not -. When you say 8 that a camera is down, that's different than 9 the whole system not recording. That's not the 10 same thing. That might be that one particular 11 camera, and whatever area that she was talking 12 about, that I believe they had to be a fight, 13 or something happening for her and I to look at 14 a camera. That particular camera may, again, 15 something might have not been programmed 16 correctly, that we were not able to rewind. 17 But that is not the same thing as a whole 18 system not being operational. 19 MR. : Okay. 20 MS. : It's two totally different 21 things. 22 MR. : Okay. So, my question on 23 this really is -- 24 MS. : And it's still fine. 25 MR. : -- my question on this is EFTA00127321 LIMITED OFFICIAL USE 118 1 really is 2 MS. : Mm-hmm. 3 MR. : -- regarding 4 because it sounds like was told to fix 5 the issue, and that's really why I'm asking 6 this question. Do you know if was 7 instructed that you need to fix this issue? 8 MS. : You said in SHU? 9 MR. : Well, no. This is just 10 the cameras in general. 11 MS. (Indiscernible *01:52:06). 12 MR. : Well, we learned that the 13 cameras in SHU weren't recording. 14 MS. : Okay. 15 MR. : Through the 16 investigation. And to find -- 17 MS. : Mm-hmm. 18 MR. : -- and determining, well, 19 when was this first found out? This is 20 MS. : Okay. 21 MR. : -- you know, that there 22 was a problem with the cameras. You know, we 23 obviously had to talk to a lot of people, 24 including, you know, , and , and, 25 you know -- EFTA00127322 LIMITED OFFICIAL USE 119 1 MS. : Now, that, now, I would like to 2 ask you to, did ever say that he knew 3 that the whole camera system was not working, 4 and when he knew, and who he had a conversation 5 with? 6 MR. : No, no, no. 7 MS. : About it. 8 MR. : So, that -- 9 MS. : Oh. 10 MR. : -- so, the understanding 11 that I am of, is that - and again, I know at 12 least spoke with , and she 13 believed that you were with her when the 14 conversation took place. So, that is where I 15 was asking if you recall having a conversation 16 with and 17 MS. : I recall that, but not about 18 the camera system. The whole Nice system. And 19 all of the cameras in SHU not recording. 20 MR. : Yeah. Right. And I'm 21 not saying that that would have been the 22 conversation. I would think that the 23 conversation would more be along the lines of, 24 hey, we are trying to review this video. We 25 are not able to do it. Can you figure out EFTA00127323 LIMITED OFFICIAL USE 120 1 what's going on with the cameras? 2 MS. : If that, if we had a 3 conversation about that, then I could see, 4 logically, that, yeah, I would say, 5 hey, why we can't rewind? 6 MR. : Sure. 7 MS. : Can you fix a camera, X, Y, and 8 Z, or see why it's not focused, or something to 9 that effect. 10 MR. : Right. And so, my 11 question -- 12 MS. : Yeah. Yeah. 13 MR. is to you 14 MS. : Yeah. 15 MR. : -- do you remember what 16 the conversation entailed? 17 MS. : I can't remember the 18 conversation, but I know, if we were talking 19 about a particular image, or a particular 20 camera, and again, I'm not saying that it's not 21 recording, we are saying that we can't rewind, 22 that is what it would have been about. 23 why can't we rewind? Why can't we pull up 24 camera X, Y, and Z? But not about the whole 25 system. Especially if the whole system was not EFTA00127324 LIMITED OFFICIAL USE 121 1 in question. Or there was no talk about the 2 system not recording, or even SHU not 3 recording. There was never any conversation 4 about SHU, or anything. So, that's the 5 conversation would have been limited to that 6 particular camera, and why we can't rewind. 7 MR. : Absolutely. And then -- 8 MS. : And -. 9 MR. : -- that is kind of my 10 understanding -- 11 MS. : Yeah. 12 MR. : -- is what your part of 13 this conversation was, is we are having an 14 issue trying to record, can you figure it out? 15 And my question to isn't, like, you know, this 16 isn't an I gotcha type of question, even in the 17 slightest. It's just, if you can -- 18 MS. : Yeah. 19 MR. : -- recall what 20 conversation you had with 21 MS. : I can only recall about that, 22 like you said, about the interaction with 23 and I talking about why we were not able 24 to rewind to see what happened. Because we 25 were able to pull the image up. We were just EFTA00127325 LIMITED OFFICIAL USE 122 1 not able to rewind. So, that is what I'm 2 saying. There is, and it might sound like I'm 3 trying to be very specific and deliberate, 4 because I am, because there is a difference 5 with you accessing the Nice system, and I'm not 6 an electronic - an electrician - or, you know, 7 an electronics person, and I could physically 8 see it, I could see it, but I am not able to 9 rewind. That doesn't let me know that, oh, the 10 system is not recording. So, that would not 11 have ever been part of the conversation. The 12 conversation would have been limited to, why is 13 it that I am able to look at it, but I can't 14 rewind? 15 MR. : Sure. Now, do you know 16 anything about -- 17 MS. : So, figure that out. 18 MR. and do you know if, do 19 you know if Lieutenant created a memo, 20 and provided it to , regarding the camera 21 issue on the 8th? 22 MS. : No. Now, if she included me in 23 it, then I would say, oh, okay -- 24 MR. : But you -- 25 MS. : -- but I don't -- EFTA00127326 LIMITED OFFICIAL USE 123 1 MR. : -- yeah. And I don't 2 know that she would have included. She said 3 that she wrote a memo, based upon the issue 4 with the camera, and provided it to Captain 5 6 MS. : No. 7 MR. : But -- 8 MS. : Hmm-mm. 9 MR. : -- but when you -. But 10 you do remember when, you know, in her, like I 11 just read to you, she said that the 12 conversation with the problem with rewinding 13 actually was with you and , though? Do 14 you remember being present for that, you 15 know -? 16 MS. : Now, I don't know if was 17 present for that. But I do, I know, because of 18 you reciting about the conversation, I do know, 19 definitely, that was there, and if she 20 is saying that was there, it is -. 21 Gosh, I don't know see why she would say he was 22 or he wasn't. It didn't have great importance 23 to me, that conversation, because it wasn't -. 24 So, that is why I am not, I am not - I can't 25 recall this to say that, oh, this person was EFTA00127327 LIMITED OFFICIAL USE 124 1 there, that person was there, because it 2 wasn't, it wasn't, in my mind, highlighted that 3 the camera system was down. So -- 4 MR. : Okay. So, what we have 5 learned is that, that is when checked on 6 the system, and he realized that - and this, 7 there is nothing that we learned that, you 8 know, have any knowledge of this, so I will 9 just, you know, put that out front - is that 10 said he checked on the system, and he 11 realized that two of the drives were down, and 12 when two drives go down, it stops the system 13 from recording. So, half of the cameras in the 14 institution stopped, were not recording at the 15 time. And this was basically learned on August 16 8th and August 9th, when he was trying to fix 17 the system. Were you ever made aware of that 18 information? 19 MS. : No. I was not. 20 MR. : Okay. Is this the first 21 time you are even hearing of that information? 22 MS. : Absolutely. 23 MR. : And is there someone that 24 he should have told about that information, the 25 fact that -- EFTA00127328 LIMITED OFFICIAL USE 125 1 MS. : Yeah. 2 MR. : -- no, no, no, that half 3 the cameras in the institution are actually 4 down and not recording? I mean, there is 5 live feed, but there is no recording. 6 MS. : Yeah. So, he should have 7 definitely told his first line supervisor, who 8 would have known to then tell his supervisor, 9 and if I am the common denominator, because I 10 am, I was the AW, and I probably was 11 supervising facilities at the time, that 12 information, at some point, would have made it 13 to me. 14 MR. : All right. So, this is 15 another one of those everyone seemed to be out 16 on the 9th, at least. Mr. was the 17 facilities manager, and he was actually out 18 that entire week. So, he wasn't in the know 19 that the cameras were down. So, it was just 20 MS. : There is a, there is a -. 21 Okay. So, there is his -. So, first 22 line supervisor is not actually 23 was his second line supervisor. 24 MR. : Okay. 25 MS. : His first line supervisor was EFTA00127329 LIMITED OFFICIAL USE 126 1 another person. (Phonetic Sp. 2 *01:58:34). I don't know if was working 3 at the institution at the time, but , who 4 is the facility manager, is the second line 5 supervisor. 6 MR. : Would -- 7 MS. : So, I don't -. 8 MR. : -- would be, you 9 are talking about the general foreman? 10 MS. : Yeah. The general foreman. 11 MR. : If there was no one -- 12 MS. : Yeah. 13 MR. : -- filing the general 14 foreman at the time -- 15 MS. : No. 16 MR. : -- is our understanding. 17 MS. : So, there was not even an 18 acting in place? 19 MR. : Yeah. From out 20 of office response, to the people that acted in 21 his stead, where , and I think her 22 name was 23 MS. : Oh. Oh. 24 MR. : But -- 25 MS. : Acting in his place. EFTA00127330 LIMITED OFFICIAL USE 127 1 MR. : -- right. So, but there 2 wasn't an acting for the general foreman. From 3 our understanding is that there was just no one 4 in the general foreman role at the time, and 5 that's, unfortunately, on the 9th, there is a 6 lot of people that were out of the institution, 7 and a lot of people that were not there, that 8 would have -- 9 MS. : Then -- 10 MR. : -- potentially been in 11 the know in these situations. 12 MS. : -- then he could have 13 contacted, he should have contacted somebody. 14 I mean, if you are all - and I'm just going to 15 say line staff, but they are all peers, they 16 are all subordinates, and no one is a 17 supervisor. If there is something that, that' 18 a security issue, you would raise it to 19 someone, of a supervisory nature. And if your 20 supervisor is not there, you would raise that 21 to the next level, who was, in the absence of 22 your supervisor, your supervisor's supervisor. 23 MR. : And do you know, so, 24 according to , this is something that 25 happened quite regularly. EFTA00127331 LIMITED OFFICIAL USE 128 1 MS. : Mm-hmm. 2 MR. : That these things would 3 go down, he would have to rebuild the system, 4 and then the cameras would be down for, you 5 know, a period of 24 hours, while the system 6 rebuilt. Were you aware of that? 7 MS. : Hmm. No. I know, after the 8 fact, there have been issues that we were aware 9 of with the camera. But prior to, and again, 10 arrived at the institution in July 11 MR. : Sure. 12 MS. so, this is one-month in. 13 So, if there were historical issues with the 14 camera, I have no way of knowing what existed 15 because I was not present then. But at the 16 time that I was present, there is no mention of 17 those cameras being down. And again, because 18 of that incident, there was obviously 19 heightened attention to the cameras, and who 20 you should notify when you are aware that a 21 camera is down. But at the time, when I was, 22 you know, like I said, a recent arrival, there 23 was no mention or a discussion that I was aware 24 of about any issues with the camera. 25 MR. : Okay. So, leading up to EFTA00127332 LIMITED OFFICIAL USE 129 1 this issue, you didn't know that the cameras, 2 they are a big problem at the institution? 3 MS. : You said leading up, or 4 following the incident? 5 MR. : No. Leading up to the 6 incident. 7 MS. : You said, did I have any 8 knowledge of it? 9 MR. : Right. 10 MS. : Yes. Leading up to the 11 incident, there was no knowledge that there was 12 issues with the cameras recording. 13 MR. : Okay. And do you know if 14 - when you and Lieutenant were speaking 15 with - do you know if he was told to fix 16 the camera situation immediately? Or to just 17 look into it and figure out what's going on. 18 Do you recall? 19 MS. : I don't -. I don't want to -. 20 I don't want to -. I don't recall my exact 21 words to him. But again, if there was no 22 mention that the camera was not recording, 23 there is a difference when instruction, based 24 on knowledge that the cameras are not working, 25 versus knowledge that the camera that I can see EFTA00127333 LIMITED OFFICIAL USE 130 1 it, but I can't rewind it: 2 MR. : Sure. 3 MS. : And not -- 4 MR. : So, you 5 MS. : -- knowing -- 6 MR. : -- so, you knew that 7 there was an issue with the camera. You just 8 didn't know what the issue was. 9 MS. : I knew that we could not 10 rewind. Yes. 11 MR. : Okay. 12 MS. : Yes. 13 MR. : And do you remember if 14 you ever followed up, after that conversation, 15 with anyone, to say, hey, did that ever get 16 resolved? 17 MS. : I don't. I don't recall. 18 MR. : Okay. Is there a reason 19 why you should have, or did you believe someone 20 else was on top of it, and that was fixing it, 21 and looking into it? 22 MS. : I don't (Indiscernible 23 *02:02:48). I don't -. I actually, I don't 24 recall because, again, at the time, when we 25 were looking at the camera, you can see it. EFTA00127334 LIMITED OFFICIAL USE 131 1 So, there was, there was never any discussion, 2 or there was never even no information to say 3 that the camera was not working. There was 4 never any discussion about that. So, to follow 5 up on an issue that you don't know is present, 6 I would say that that's, if I didn't have a 7 further discussion about it, it's because of 8 that, that there was no discussion that the 9 camera was not recording. 10 MR. : Okay. So, from the 11 knowledge that you do have, that, you know, you 12 know, according to , she was saying she 13 knew that the cameras weren't recording, and 14 they were down. And then, saying that 15 he was going to fix them, and he clearly knew 16 the cameras weren't recording. What should 17 have happened? 18 MS. : Well, first, I want to clarify, 19 you are saying that said that she knew 20 the cameras were not recording. 21 MR. : She - yeah - her -. That 22 is what i read you before - that she said, her 23 words, "Notifying him that the camera was down, 24 and trying to go back and look at the footage, 25 and I can't." And then, later on -- EFTA00127335 LIMITED OFFICIAL USE 132 1 MS. : But that's not saying that -- 2 MR. : -- saying, you know, 3 saying -- 4 MS. : -- (Indiscernible *02:04:10). 5 MR. : -- so, okay -- 6 MS. : Yeah. 7 MR. : -- the two of them knew 8 the cameras were down. Yes. And then, she 9 said that she actually wrote a memo to the 10 captain, saying that, you know, the cameras 11 were down, and that was fixing the 12 issue. And then, when he came in on the 10th, 13 to find out the cameras still hadn't recorded, 14 she had a conversation with and said, 15 hey, you told me you were going to fix the 16 cameras. Why didn't you fix them? So, I'm not 17 saying that you have any part of this. What 18 I'm saying 19 MS. : Oh. 20 MR. : -- you, is -- 21 MS. : No. I know -- 22 MR. : -- being that Lieutenant 23 seems to have known that the cameras 24 were down, and definitely knew the 25 cameras were down, what should have happened? EFTA00127336 LIMITED OFFICIAL USE 133 1 MS. : Then someone should have 2 followed up to say were the cameras, if saying 3 down means not recording. 4 MR. : Right. And that's what 5 they -- 6 MS. : That's (Indiscernible 7 *02:04:57). 8 MR. : -- and that was clear. 9 went into, you know, great detail of, 10 the cameras, you could watch live, it's only 11 when you try to rewind, because they weren't 12 recording. And he said 13 MS. : That's -- 14 MR. : -- this is what happened 15 16 MS. (Indiscernible *02:05:11). 17 MR. : -- and he -- 18 MS. (Indiscernible *02:05:11). 19 MR. sorry. Go ahead. 20 MS. : I don't know if knew 21 that what, the explanation that you said, 22 provided, that, I have never had a 23 conversation to say that the reason why you 24 can't rewind is because the cameras are not 25 recording. I don't know. I can't say what EFTA00127337 LIMITED OFFICIAL USE 134 1 knew. If she understood that that's 2 what that meant. I know that I know that 3 that's -. I did not know that that's what that 4 meant. So, if never came back, and 5 said, oh, the cameras are not recording, that 6 is a difference with then just saying that, oh, 7 you could see the camera, you are thinking that 8 the camera is working. If you pull up a camera 9 on the Nice Vision (Phonetic Sp. *02:05:52), 10 and you could actually see the image and 11 everything, you are thinking that the camera is 12 recording. So, how else would -? Why else 13 would you think that it's not recording? 14 MR. : Well, that's why -- 15 MS. (Indiscernible *02:06:02) 16 MR. : -- that's why I'm trying 17 to explain to you -- 18 MS. (Indiscernible *02:06:04). 19 MR. : -- like, said that 20 she knew that they weren't. That's why she 21 wrote the memo to the captain, and that's why - 22 23 MS. : Yeah. 24 MR. : -- on the 10th, when she 25 found out that the cameras were still down, she EFTA00127338 LIMITED OFFICIAL USE 135 1 confronted and said, you were supposed 2 to fix this, why didn't you fix the cameras? 3 MS. : Hmm. 4 MR. : So, those two things is 5 what I'm trying to -. I've been trying to 6 explain to you -- 7 MS. : Oh. 8 MR. : -- is that she did know, 9 is because that is why she wrote the memo to 10 the captain, and that is why she confronted 11 on the 10th, saying why didn't you fix 12 this? 13 MS. : And my response then would be: 14 maybe she thought - and I'm not, I don't even 15 want to -. I don't know. Maybe -- 16 MR. : And she didn't point the 17 18 MS. : -- (Indiscernible *02:06:42). 19 MR. : -- she didn't point the 20 finger at you in the slightest. I'm not even 21 trying to insinuate that. 22 MS. : Mm-hmm. 23 MR. : I'm saying, because you 24 are the AW in charge of -- 25 MS. : Yeah. EFTA00127339 LIMITED OFFICIAL USE 136 1 MR. : -- you know, this 2 situation, what should have happened? And this 3 4 MS. : Mm-hmm. 5 MR. : -- and again, isn't 6 gotcha. I'm asking you -- 7 MS. : Mm-hmm. 8 MR. : -- as a genuine question. 9 Like, you're the boss. What should have they 10 done? 11 MS. : Yeah. Someone should have 12 specifically said the cameras are not 13 recording. And I'm not going to say it's 14 responsibility, but she reported it. 15 If she reported it to her supervisor, she did 16 what she was supposed to do. So, I'm going to 17 kind of -. Like you said, I'm going to try to 18 come back and be, like, really assess it. If 19 she reported it to her supervisor, that's her 20 responsibility. 21 That's what she did. But from there, it - 22 I wish had said to me, hey, I 23 received this memo from , saying that the 24 cameras are not working. And that I spoke with 25 , and the cameras are not working, they EFTA00127340 LIMITED OFFICIAL USE 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 are not I could have to recording. And have definitely do overtime, in 137 that is something that said, okay, f you the absence of your supervisor, I am authorizing you to do overtime, to then fix the cameras, and then, when something like that happens, obviously, you know you have to make security related decisions. Then you could have recalled all the inmates, so that if there is any incidents that happened, at least the inmates are confined to their cells. And then, you say, well, there is no cameras inside of the cells. But you make rounds. You have to make rounds in Special Housing anyway. You know? So, you wouldn't be able to capture what's happening inside of the cell itself. But you would have a general idea about, you know, with the cameras, what's going on. But there would have been decisions that would have been made, to ensure security. But there should have been notification, and clarification, and specificity about - specificity - about actually what was the issue. EFTA00127341 LIMITED OFFICIAL USE 138 1 MR. : Okay. So, in your 2 opinion, though, it's, should have 3 reported it to should have made 4 the appropriate - like, this is, I'm not saying 5 that this did or didn't happen. I'm just 6 saying, under, from what you know -- 7 MS. : Mm-hmm. 8 MR. should have 9 told should have made whatever 10 appropriate, you know 11 MS. : He should have told -- 12 MR. : -- taken whatever actions 13 needed to be taken. 14 MS. : -- he should have -. Yeah. 15 Then, if I was his supervisor, then he should 16 have told me. 17 MR. : Okay. And again, it 18 sounds like this is how - you already answered, 19 but to be clear - you knew there was a problem 20 with that one specific incident, trying to 21 rewind, but you had no idea what the problem 22 was. You just knew you weren't able to rewind. 23 MS. : And - yeah - if you simplify 24 it. Yeah. 25 MR. : Right. So, you didn't EFTA00127342 LIMITED OFFICIAL USE 139 1 know that the -- 2 MS. : Mm-hmm. 3 MR. : -- point being, you 4 didn't know the cameras were down. 5 MS. : Yeah. 6 MR. : You didn't know that they 7 were not recording. 8 MS. : Exactly. 9 MR. : Great. So, were you 10 aware that MCC cameras were scheduled to be 11 replaced? 12 MS. : Hmm. No. I didn't know that 13 they were scheduled to be replaced. I know - 14 again - there is information that you -. I 15 don't know if they were scheduled to be 16 replaced. I know that they have been, they 17 were upgraded after. And then, I know there 18 was certain projects. But I don't -. I, 19 again, I don't know what I -. That, if they 20 were scheduled to be replaced at the time of 21 the incident. 22 MR. : So, I guess what I'm 23 saying is, do you know if they were, you had 24 new cameras on site at the MCC, and there was 25 currently a camera project underway, of EFTA00127343 LIMITED OFFICIAL USE 140 1 replacing the old cameras? Did you know that? 2 MS. : No. Not at the time. 3 MR. : Okay. 4 MS. : Not -. Not at the time. 5 MR. : So, based on the work 6 orders and email communications that we 7 received -- 8 MS. : Mm-hmm. 9 MR. : -- the MCC ordered new 10 cameras, DVRs, and other system parts, and had 11 them delivered to the MCC in approximately 12 October of 2018. 13 MS. : Mm-hmm. 14 MR. : These were the cameras 15 that were installed immediately after Epstein's 16 death in August of 2019. 17 MS. : Hmm. 18 MR. : Did you know that to be 19 accurate? 20 MS. : I know that there were cameras 21 that were installed after, and afterward, but 22 again, I don't know when those cameras arrived 23 because I didn't work there in 2018. 24 MR. : Sure. Sure. 25 MS. : No. EFTA00127344 LIMITED OFFICIAL USE 1 MR. : But I guess what I'm 2 saying, though, is -- 3 MS. : Oh. 4 MR. : -- did you know that 5 those cameras were on site, and they were, you 6 know -- 7 MS. : No. 8 MR. : -- you didn't even know 9 that? 10 MS. : No. There's a lot of things 11 that have, obviously that folks have knowledge 12 of after the fact because of the incident, and 13 there have been actions after, but there was 14 no, I was not knowledgeable about cameras being 15 on site, and about the installation prior to. 16 MR. : And just to be clear. 17 So, , you know, the facilities manager -- 18 MS. : Mm-hmm. 19 MR. : -- you know, Warden 20 , and, you know, , they have all 21 said, yup, this is accurate. So, the follow up 22 on that is, when should the new camera system, 23 that was already on site at the MCC, have been 24 installed? Do you have even a -? Or do you 25 just not have knowledge on that because you EFTA00127345 LIMITED OFFICIAL USE 142 1 weren't there at the time? 2 MS. : Yeah. So, I don't have 3 knowledge of that. 4 MR. : Okay. Do you know who 5 would have been ultimately responsible for 6 ensuring -? Because it sounds - and again, you 7 weren't there at the time, but there was a lot 8 of problems, the same problem happened time and 9 time again, at the MCC, where these cameras 10 would -. Two hard drives would crash, and then 11 take out the system. And then, would 12 have to go and rebuild the system, and it was, 13 like, a 24 hour process to rebuild it. 14 MS. : Mm-hmm. 15 MR. : Who should have made sure 16 that new camera system was installed? That was 17 on site. Who should have, like, said, like, 18 this is an urgent matter? And I am assuming it 19 was. Was that an urgent matter, if the cameras 20 are down? 21 MS. : Mm-hmm. Yeah. 22 MR. : And they are not 23 recording? I would think that that's a pretty 24 big deal. Correct? 25 MS. : Mm-hmm. Correct. EFTA00127346 LIMITED OFFICIAL USE 143 1 MR. : So, who should have made 2 sure that that new system was installed? That 3 had been on site, all the way back to October 4 2018. 5 MS. : It's multi-layered. And when 6 it's a multi -. This is multi-layered. Because 7 if you are saying that, who actually does the 8 work for the installation, or who the primary 9 person is the electronics technician. But 10 ultimately, they have a supervisor, and that 11 supervisor tracks the completion of projects. 12 The progress of projects. So, it's - that's 13 what I'm saying - it's multi-layered. That, 14 and if the cameras were present, I don't know 15 what would have happened to make them not be 16 installed. 17 MR. : And just for more -- 18 MS. (Indiscernible *02:13:50) 19 MR. : -- information, the 20 reason why they were on site, the reason why 21 you guys were able to get your cameras 22 immediately back up and running, with a whole 23 new system, was because they were already on 24 site. So, knowing that information, what is 25 your thought on the matter? Like, the fact, EFTA00127347 LIMITED OFFICIAL USE 144 1 now that you are hearing, and again, this is, 2 I'm looking at you as a subject matter expert. 3 I am not looking for any type -. 4 I'm not accusing you of anything. I'm 5 just looking at you as you are a boss there. 6 You are in charge of custody. So, I am just 7 kind of giving you this information, so you can 8 give me your professional feedback. So, the 9 fact that they were able to immediately install 10 this, have SigNet come in, who was the 11 contracted company, and install these new 12 cameras that had been on site since October of 13 2018 -- 14 MS. : Mm-hmm. 15 MR. : -- what is your opinion 16 on that? 17 MS. : Hmm. 18 MR. : Do you think that they 19 were, you know, the MCC, or, you know, really 20 dropped the ball with having this faulty camera 21 system, and actually having the parts that they 22 needed on site, to be able to be replaced? 23 MS. : I'm careful with saying about 24 this, who dropped the ball. I know if you know 25 that there is cameras present. And there is no EFTA00127348 LIMITED OFFICIAL USE 145 1 logical reason why the cameras can't be 2 installed. And if it is your department that 3 is responsible for installing the cameras, then 4 you should ultimately ensure that the cameras 5 are installed. And -. 6 MR. : Now, should - would it 7 fall on the facilities manager to make sure 8 that that's happening? 9 MS. : The Comtech works for the 10 facility manager. So, the facility manager is 11 responsible for the department that that staff 12 member works in. 13 MR. : So -- 14 MS. : You know? 15 MR. : -- according to 16 he said that his job was basically to fix it. 17 His job, you know, fix things when they're 18 broken. And he had been screaming that there 19 was a problem with these camera systems for a 20 long time, and he's basically the reason why 21 they got the new cameras, but he said, you 22 know, it wasn't his job to get SigNet there, to 23 be able to actually get these installed. 24 You know, so, that is where, to me, 25 hearing that explanation, it sounds like oh, EFTA00127349 LIMITED OFFICIAL USE 146 1 well, it's really probably the facilities 2 manager that is, you know, supposed to manage 3 that task, and make sure that they get in 4 there. But I don't -. I want to make sure 5 that that would be an accurate, you know, 6 assessment, or if I'm off. 7 MS. : Now, would have -. I don't know 8 if, like you said, if it's the facility manager 9 that actually calls SigNet, or if it is the 10 Comtech that would call and coordinate SigNet's 11 visit. It's between the two. 12 MR. : So, you believe they 13 have, both have part responsible --- 14 MS. : Mm-hmm. 15 MR. : -- you know -- 16 MS. : Mm-hmm. 17 MR. : -- their part exposure to 18 this thing? 19 MS. : Yeah. 20 MR. : And anything -- 21 MS. : Yeah. 22 MR. anyone outside of the 23 facilities manager? I mean, did this go up to 24 the executive, you know, level, to the captain, 25 AWs, or warden? EFTA00127350 LIMITED OFFICIAL USE 147 1 MS. : If they were aware that the 2 cameras were there, and that the cameras should 3 have been installed. Now, and that's what I'm 4 saying, I don't know if, who knew that the 5 cameras were there. 6 MR. : Yeah. I mean, certainly, 7 the warden did. 8 MS. : Or that -- 9 MR. : But -. 10 MS. : -- that it shipped. Mm-hmm. 11 MR. : So, if the -- 12 MS. : Mm-hmm, 13 MR. : -- warden knew that, is 14 that something you think that he has exposure 15 to, then, as well? 16 MS. : Hmm. Oh my gosh. If - again, 17 without knowing who knew what, I don't, I don't 18 know who -. This is -. Yeah. 19 MR. : Sure. 20 MS. : No. 21 MR. : No. And that's fine. 22 And point being, though, you didn't know that 23 the cameras were even there. It sounds like 24 you are saying? 25 MS. : I would have no knowledge to EFTA00127351 LIMITED OFFICIAL USE 148 1 know about the cameras were there, because this 2 all happened prior to me. 3 MR. : Right. No. I'm just 4 saying -- 5 MS. (Indiscernible *02:17:39). 6 MR. : -- like, you know, you 7 were -- 8 MS. : Yeah. No. 9 MR. : -- you were -- 10 MS. : No. 11 MR. : -- you were, I know it 12 was only a month and a half, but you were 13 there, leading up to this point. I just didn't 14 know if that was a conversation that would be 15 happening within executive staff meetings, 16 that, hey, this is where we are on the camera 17 project. You know, and -- 18 MS. : Well, now -- 19 MR. : -- we'll be -. 20 MS. conversations about the 21 camera project, and again, I'm going to 22 reiterate what I've kind of said before, 23 because of this incident, there have been 24 discussions about things that happened within 25 this incident, but that's after the fact. EFTA00127352 LIMITED OFFICIAL USE 149 1 MR. : And so, prior 2 MS. you're asking -- 3 MR. : -- prior to August 10th, 4 that you weren't involved in the conversations 5 at all with the camera project? 6 MS. : I do not recall anything 7 specifically about discussing about camera 8 project. 9 MR. : Great. 10 MS. : Now, if you can, if you can 11 show me something, or anything to that effect, 12 then I can say, okay, yes. 13 MR. : No, no, no, and again, 14 this is not an I gotcha interview. This is 15 just to ask -- 16 MS. : No. I know. 17 MR. : -- you know -. 18 MS. : I know. But I'm being 19 forthcoming, so that's why I'm trying to tell 20 you. In your investigation, I know you are 21 aware, you've had conversations with folks that 22 are giving you information, but this is 23 information after the fact. 24 MR. : Right. And then -- 25 MS. : So -. EFTA00127353 LIMITED OFFICIAL USE 150 1 MR. : -- and point being is you 2 don't recall anything prior to, about -- 3 MS. : No. 4 MR. : -- a camera project. You 5 are not -. You weren't aware that there was a 6 - at least at this moment in time - you don't 7 recall there ever being a camera project 8 leading up to the incident? 9 MS. : I do not recall. Hmm-mm. 10 MR. : Okay. 11 MS. : I did -. Yeah. I don't 12 recall. Mm-hmm. 13 MR. : Okay. So, now, we are 14 going to touch on cell assignments. Then we're 15 going to just try to fly through the rest, 16 because that was the primary things I wanted to 17 talk to you about, were the cameras and Reyes. 18 MS. : Mm-hmm. 19 MR. : So, these are more just 20 to touch on some things. 21 MS. : Mm-hmm. 22 MR. : Now, are you aware that, 23 on August 9th and 10th, 2019, Epstein was not 24 in his assigned cell, as documented within the 25 BOP cell assignment history, and the BOP EFTA00127354 LIMITED OFFICIAL USE 151 1 database? 2 MS. : Can you say that one more time? 3 I'm sorry. 4 MR. : So, were you aware, are 5 you aware of anything with a cell discrepancy, 6 with Epstein, that he was, he was physically in 7 a cell that didn't correspond with the BOP 8 system? 9 MS. : Yes. And this information 10 after, after the fact. 11 MR. : And do you know why 12 Epstein wasn't in his assigned cell, according 13 to the BOP database? 14 MS. : Sheer error. 15 MR. : And do you know who made 16 that error? 17 MS. : Not - no - not specifically. I 18 don't know who made the error. 19 MR. : So, what do you know 20 about it? 21 MS. : I know that there were keying 22 errors. And so, Sentry reflected one cell 23 assignment, but he was physically in another 24 cell. 25 MR. : And do you -? So, he was EFTA00127355 LIMITED OFFICIAL USE 152 1 in that cell from the time he, you know, 2 assigned to that cell in Sentry, from July 3 30th, all the way to August 10th. 4 MS. : Mm-hmm. 5 MR. : So, being that he was 6 there for, you know, ten or 11 days -- 7 MS. : Mm-hmm. 8 MR. : -- should that have been 9 caught in that period of time? 10 MS. : Yes. 11 MR. : And who should have 12 caught that? 13 MS. : The folks that are doing the 14 rounds. 15 MR. : So, is that, that falls 16 onto the SHU staff? 17 MS. : If - yeah - if it happened in 18 GP, it would have fallen on the person that is 19 actually doing the rounds in GP. So, yes. Mm- 20 hmm 21 MR. : Okay. And then, would 22 any lieutenants, whether it be the SHU 23 lieutenant, or the captain, or, you know, ops, 24 activities lieutenant, should any of them 25 caught this? EFTA00127356 LIMITED OFFICIAL USE 153 1 MS. : Well, they would have only 2 known that if they actually looked at a roster, 3 and physically walked with a roster, to know 4 which cell he was in. But I'm thinking about 5 the 292s, whether or not it would have the cell 6 on it. I'm not sure if the 292 -. Do you know 7 what I'm talking about when I say 292? 8 MR. : Yeah. His file that is 9 kept in the housing unit. 10 MS. : Does it have this -? I'm not 11 even sure if it has the cell number on it. But 12 the long and short of it, you are making 13 rounds, you're pulling the inmate in and out of 14 his cell, you're keying, because 15 MR. : Now, are you talking 16 about bed book count, or are you talking about, 17 like, actual rounds? 18 MS. : No. You're making rounds. Not 19 a bed count. If you actually did it, if a bed 20 book was done, between those days, then whoever 21 did the bed book would most definitely know 22 that there was an error. Because you have to 23 have the roster with you. But without, if a 24 I don't know if a bed book count was during 25 that time. I know that the counts were done EFTA00127357 LIMITED OFFICIAL USE 154 1 after the fact. 2 MR. : And is there a -- 3 MS. : (Indiscernible *02:22:36). 4 MR. -- requirement to do, 5 like, a bed book count, like once a week, or 6 any certain amount of days, or -? 7 MS. : There is no, there is no 8 requirement that says a bed book count has to 9 be done once a week. That was -. There was 10 some procedures put in place after the fact. 11 MR. : Okay. And is, and how do 12 we determine if a bed book count was in fact 13 conducted? 14 MS. : Without there being some 15 documentation, or to say, or, because I know 16 after the fact, like I said, when that was a 17 procedure put in place, it was indicated that 18 that should be documented in the log. 19 MR. : But that was an after the 20 fact thing? So, it wasn't 21 MS. : After. 22 MR. : -- being documented prior 23 to? 24 MS. : No. It wasn't. It wasn't done 25 prior to. Now, if you are making, TruScope, EFTA00127358 LIMITED OFFICIAL USE 155 1 the officers have a log that they do. Any 2 activity is part of whatever is going on in 3 your unit. That should have That could 4 have been logged. But is there a requirement 5 that said that you have to log that, that you 6 did the bed book count? You would be doing it, 7 you know, for documentation purposes. But a 8 lieutenant or a staff member can do a bed book 9 count, just to make sure that things are done 10 accurate. So, that's not -. It's not 11 something that was a requirement prior to. 12 MR. : Okay. So -- 13 MS. : Mm-hmm. 14 MR. : -- aside from the bed 15 book count, though, is there any other way, 16 though, and you said when they were conducting 17 rounds. I mean, when a staff member is 18 conducting rounds, are they supposed to be 19 walking around with the, you know, Sentry 20 report, or BOP roster, or whatever it is, the 21 housing roster that indicates what cell he is 22 assigned to in the system? 23 MS. : No. They don't have to have 24 the roster. However, once the inmate is 25 introduced into SHU, typically, the OIC does a EFTA00127359 LIMITED OFFICIAL USE 156 1 lot of the data entry. So, someone, even if 2 it's not the OIC, if someone in SHU, if someone 3 is doing the data entry, they are the ones that 4 is physically recording where the inmates is. 5 No one else would know where that inmate was 6 assigned unless they actually go in the system 7 and do the Sentry assignment. So -- 8 MR. : Okay. 9 MS. : -- the person that is saying, 10 okay, if I am saying put inmate X, Y, and Z in 11 cell ten, I have to change him from wherever he 12 was before, and make sure that I update, I 13 update it. And not only that, there is a 14 physical board in SHU that you have the cards. 15 You have name tags or whatever. And it shows 16 where everyone is. 17 MR. : And does it say where 18 they are based upon them writing it down from 19 knowing that they are in there, or is that 20 showing where they are based upon what the BOP 21 system says? 22 MS. : From knowing where - from 23 knowing where they are. 24 MR. : Okay. 25 MS. : So, the system, and everything EFTA00127360 LIMITED OFFICIAL USE 157 1 should be the same. So, if I'm changing, if 2 I'm changing an inmate's Sentry assignment, 3 then I know I - I automatically know there is 4 not just one thing I have to do, there is a 5 couple of things I have to do. 6 MR. : Mm-hmm. 7 MS. : I have to physically move the 8 body from one place to another. 9 MR. : Okay. 10 MS. : I have to put the card, you 11 know, the card off of one door, put it on the 12 new door, and I know I have to update Sentry 13 because Sentry should be accurate. I 14 physically have to do a PP - I can't remember - 15 34, and then update the Sentry assignment. And 16 then, I should physically update the board, so, 17 the door and the board would have cards on 18 them, or, you know -- 19 MR. : And this is where, so, _ 20 know what happened. I know what happened when 21 this all happened on the 30th. On the - I know 22 what happened, how it was done, where the 23 discrepancy came in place. So, I guess my 24 question, though, is: between - and so, I know 25 that the person who dropped, you know, EFTA00127361 LIMITED OFFICIAL USE 158 1 basically dropped the ball by not making the 2 correct entry on the 30th, but the fact that 3 from the 30th all the way to the 10th -- 4 MS. : Mm-hmm. 5 MR. : -- this, you know, 6 discrepancy continued, my question to you is, 7 is there any point, aside from when he was 8 physically placed in the wrong cell, and the 9 key entry wasn't, you know, updated, or not in 10 the wrong cell, but they key entry wasn't 11 updated. Was there any way that that would 12 have been caught in those approximately ten 13 days? After that initial mistake happened. 14 So, like, an audit of the system -- 15 MR. : Yeah. 16 MS. : -- or, like, hey, let's, 17 you know, aside from a bed book count, how do 18 we know that these inmates are actually in the 19 cells that they are supposed to be assigned, 20 you know, or they are in the cells that they 21 are assigned in, in the system? Is there a 22 checks and balance to that? Are they -? Is 23 there -? Is the staff supposed to be checking 24 those sheets, or is it -? Is there an audit 25 that is done by the lieutenant or the OIC? EFTA00127362 LIMITED OFFICIAL USE 159 1 MS. : I wouldn't say that there is an 2 audit done, but you -. That's (Indiscernible 3 *02:27:56). That's 7/30 to 8/10. That -. 4 There is not a specific audit that is done on a 5 daily basis. There is not an audit that is 6 done besides, like I said, you making rounds -- 7 MR. : Mm-hmm. 8 MS. and you -. Yeah. I can't 9 think of a specific, like you said, a procedure 10 in place that you would check, where you would 11 audit on a daily basis, besides if you were 12 actually required to do a bed book count. 13 Which, she was not required to do a bed book 14 count daily. 15 MR. : Right. And at the time, 16 they weren't required to do them at all? 17 MS. : There was no procedure - and 18 when you say they were not required - there i.- 19 times when -- 20 MR. : I mean, based upon a time 21 period. 22 MS. : -- yeah. 23 MR. : versus, like, a, you 24 know, an incorrect count. 25 MS. : Yeah. Not that I am - not that EFTA00127363 LIMITED OFFICIAL USE 160 1 I am aware of. 2 MR. : Okay. Now, just to touch 3 on cell searches. On August 9th and 10th, 4 2019, do you know how often the SHU staff were 5 supposed to conduct cell searches? 6 MS. : Oh, you are supposed to do cell 7 searches daily. 8 MR. : Okay. And is it, like, 9 supposed to be at least five per shift -- 10 MS. : Mm-hmm. 11 MR. : -- aside from the 12 morning? 13 MS. : It's five. 14 MR. : Five. 15 MS. : Yeah. Yeah. And then, you 16 annotate it in, I believe it's TruScope, so 17 that you are ensuring, and that kind of, it 18 tracks, so that there is a, so that you can 19 ensure that all of the cells have been done. 20 MR. : Okay. So, is it 21 acceptable that only one cell was entered as 22 being searched in TruScope, on August 9th, 23 2019? 24 MS. : No. You should do at least 25 five. EFTA00127364 LIMITED OFFICIAL USE 161 1 MR. : Now, do you believe that 2 if only one was entered, does that mean only 3 one was actually conducted? 4 MS. : Hmm. I wouldn't say that. But 5 because I don't -. Hmm. That would be -. I 6 would question why one was only entered. But 7 you should do five. And you should recall, 8 record all five. 9 MR. : Now, being, you know, day 10 and night watch -- 11 MS. : Mm-hmm. 12 MR. : -- are required to do 13 five, who is responsible for, one) conducting 14 them; and two) entering them into TruScope? Is 15 it the OIC that is ultimately responsible to 16 make sure that they are done, and then enter 17 them, or is it, there is no rhyme or reason to 18 who is actually responsible? Everybody is -- 19 MS. : I wouldn't -- 20 MR. : -- responsible. 21 MS. no. I wouldn't say who, 22 because the folks that actually do the, that do 23 the rounds, they are physically, you know, 24 doing the manual labor. And typically, the SHU 25 OIC, because there is not, like, five computers EFTA00127365 LIMITED OFFICIAL USE 162 1 up in SHU. There may be one or two computers 2 in SHU. And typically, the OIC is the one that 3 is logged in. And that person is doing all the 4 administrative work. So, they would ensure 5 that, okay, rounds are done. And if there were 6 bar taps, or like you said, if there were cell 7 searches done, that information is then 8 communicated from one officer to the OIC, and 9 then that person goes in and records that it's 10 done. 11 MR. : Okay. Do you know 12 anything about Epstein placing a telephone call 13 on August 9th, 2019, from the SHU? 14 MS. : You said from August 9th? 15 MR. : August 9th, 2019. Do you 16 know anything about Epstein placing -- 17 MS. : I -- 18 MR. : -- a telephone call from 19 20 MS. : -- again -- 21 MR. : -- the SHU? 22 MS. : I know, I know information 23 after the fact. Just like everybody else. But 24 the day that it happened, no, I wasn't aware of 25 the phone call the day that it happened. I EFTA00127366 LIMITED OFFICIAL USE 1, 1 know information after the fact. 2 MR. : Okay. And what did you 3 learn after the fact? And just briefly. 4 MS. : Mm-hmm. That there was a staff 5 member that allowed him to place a phone call. 6 MR. : Did you learn that it was 7 a phone call on an unrecorded line? 8 MS. : Mm-hmm. 9 MR. : Is that a yes? 10 MS. : Yes. That is a yes. 11 MR. : Okay. And then, do you 12 is that standard practice, to allow inmates to 13 make personal calls, as had been done, from an 14 unrecorded line? 15 MS. : No. That is not standard 16 practice, and the phone call should be on the 17 ITS - the Inmate Telephone System - line. 18 MR. : Now, if he didn't have 19 his pack and PIN set up -- 20 MS. : Oh, yeah. 21 MR. : -- or PIN and pack, or 22 however, which way you say it, what, what could 23 have or should have happened, if you wanted to 24 allow someone to take a - make a telephone 25 call? EFTA00127367 LIMITED OFFICIAL USE 164 1 MS. : They don't make a phone call. 2 MR. : They just don't make one? 3 MS. : They don't make one. There is 4 allowances for, like, bereavement phone calls. 5 That would be done by the Chaplain, but that, 6 too, is on a recorded line. And that is in the 7 Chaplain area. The other thing is a legal 8 phone call, and that would be on an unmonitored 9 line. But that would only be for legal 10 purposes. 11 MR. : Now, is it true, though, 12 if it was allowed to be done on a legal line, 13 if it was authorized by, you know, the captain 14 or whomever, or the case manager, unit manager, 15 should it be put on speaker phone, and 16 monitored by a staff member? 17 MS. : Policy says - I don't know - 18 but policy says that the inmates should make 19 phone calls, and it should be through the ITS 20 system. 21 MR. : And do you -- 22 MS. : But you -- 23 MR. : -- is that -? 24 MS. : -- but there is social calls 25 and legal calls. EFTA00127368 LIMITED OFFICIAL USE 165 1 MR. : Phone calls and legal 2 calls -. 3 MS. : Oh, no. I said there is social 4 calls and there is legal calls. 5 MR. : Okay. 6 MS. : And the only phone call that 7 should be on an unmonitored line would be the 8 legal call. 9 MR. : Okay. So, you don't, you 10 don't believe there is any circumstance where, 11 if it is not a legal call, that a social call 12 should be made? 13 MS. : I know policy, what I know of 14 policy, it indicates social calls, which should 15 be via ITS. 16 MR. : And do you know if there 17 was any kind of recorded line in the SHU, that 18 could have been utilized if an inmate did not 19 have a pack and PIN? 20 MS. : No. 21 MR. : No. 22 MS. : Hmm-mm. 23 MR. : There was no line. There 24 was no such line. Just a legal line? 25 MS. : No. I'm saying, there is an EFTA00127369 LIMITED OFFICIAL USE 166 1 ITS system in SHU. 2 MR. : No, no, no. What I'm 3 saying is 4 MS. (Indiscernible *02:34:31). 5 MR. : -- if someone doesn't 6 have a pack and PIN, to be able to record it, 7 do you know if there was another type of a 8 line, like you said, I think you said the 9 Chaplain has a line that people can use, that 10 for bereavement purposes, but it's still 11 recorded. 12 MS. : Mm-hmm. 13 MR. : Is there a line that is 14 still recorded, that a staff member can provide 15 to an inmate that doesn't have the ability to 16 make a call from his pack and PIN? 17 MS. : No. 18 MR. : Or -? 19 MS. : No. 20 MR. : And is that no, there is 21 no line, or no, you are not aware? 22 MS. : No, there is no line that you 23 can make a phone call from, that is recorded, 24 that is not hooked up to the ITS. 25 MR. : Okay. And when you say EFTA00127370 LIMITED OFFICIAL USE li 1 2 MS. : -- (Indiscernible *02:35:09). 3 MR. -- the ITS, what does 4 that mean? 5 MS. : Inmate Telephone System. 6 MR. : And is that -- 7 MS. : Yeah. 8 MR. : -- with reference to the 9 pack and PIN that they receive to be able to 10 put money on their cards and use 11 MS. : Mm-hmm. 12 MR. : -- or -? Yes? 13 MS. : Yeah. 14 MR. : Okay. 15 MS. : Yeah. That is a yes. 16 MR. : Okay. And what is your 17 understanding of what occurred in Epstein's 18 cell on August 9th or 10th, 2019? 19 MS. : Well, what I am aware of, 20 again, after the fact, is that he committed 21 suicide. 22 MR. : Okay. So, you believe 23 that Epstein took his own life? 24 MS. : Yes. He was the only one in 25 the cell. EFTA00127371 LIMITED OFFICIAL USE 168 1 MR. : And do you have any 2 information, with regard to anyone else taking 3 Epstein's life? 4 MS. : No. 5 MR. : Had you heard anything 6 about Epstein's cell door being left open the 7 night of August 9th, 2019, or 10th, or the 8 morning of August 10th -- 9 MS. : No. 10 MR. : -- 2019? 11 MS. : This is the first -. If that 12 happened, this would be the first time that I 13 have, of me even hearing that. I have never 14 heard that. 15 MR. : And have you heard of any 16 other cell mates in the SHU, in the SHU, with 17 their doors being left open the night of August 18 9th, 2019, or the morning of August 10th 19 MS. : No. 20 MR. : -- 2019? 21 MS. : No. I have never heard that. 22 MR. : No? And do you know if - 23 24 MS. : Never heard that. 25 MR. : -- do you know any EFTA00127372 LIMITED OFFICIAL USE 169 1 information, with regard to anyone harming 2 Epstein on August 9th or 10th, 2019? 3 MS. : No. 4 MR. : Okay. Do you know 5 anything about Epstein changing his will just 6 prior to his death? 7 MS. : Again, that's just in the news, 8 but no, I don't have any knowledge of that. 9 MR. : So, only from what you've 10 heard in the news? 11 MS. : Yeah. I don't have any 12 knowledge of that. We don't -. The BOP has 13 nothing to do with inmates' wills. 14 MR. : Okay. So, and we're just 15 going to now wrap up. It's just specific to 16 the timeline. There was an after action report 17 that was created by the BOP. So, this is 18 specifically where I am getting this 19 information, but -- 20 MS. : Mm-hmm. 21 MR. : I'm just going to ask 22 you just a couple more questions, then we will 23 be done. 24 MS. : Okay. 25 MR. : It says, "6:33 a.m., on EFTA00127373 LIMITED OFFICIAL USE 170 1 August 10th, 2019, a body alarm is activated in 2 the Special Housing Unit. SHU staff reported 3 inmate Epstein was unresponsive in cell," and 4 it says the cell, but it says Sentry does not 5 reflect this accurately. "Staff entered the 6 cell and attempted to wake inmate Epstein. 7 Control center announced a medical emergency, 8 and CPR was initiated." So, the information 9 that we have is that at 6:33, told 10 call in the emergency, and went straight 11 into the cell. Did act appropriately by 12 going straight into the cell, or should he have 13 waited for someone to arrive? 14 MS. : No. There is -. Well, it 15 depends if you feel like you - that is an 16 emergency, and it is a life or death situation. 17 I don't know if he had the -. He could have 18 gone into -. He could have gone into the cell. 19 MR. : Okay. So, policy doesn't 20 dictate that you are supposed to wait for other 21 people to arrive, so that if it was a 22 MS. : Yeah. 23 MR. : -- a ruse, that someone 24 could have overpowered him, and then taken -? 25 MS. : There is no -. When you say EFTA00127374 LIMITED OFFICIAL USE 171 1 policy, policy does state that you have to be 2 safe, and that you should wait for another 3 staff to arrive. Policy does say that. If 4 felt that he had enough staff on hand, I 5 don't know if he felt that, but policy does say 6 to ensure. And especially if you have more 7 than one inmate in a cell. So, with, I guess 8 realized there was only one inmate in 9 the cell, and if he saw the inmate hanging, he 10 would probably want to act immediately. But 11 policy protects you either way. If you feel 12 that you have enough, because - and that's your 13 - that's what I said - that's your discernment. 14 If you feel that you have enough people on, you 15 know, available, maybe he felt that way. 16 MR. : Okay. And then, it says, 17 "At 7:36 a.m., inmate Epstein pronounced dead 18 by the emergency room physician." Do you know 19 of anything about -? Do you know if Epstein 20 ever showed signs of life, prior to leaving the 21 MCC, or specifically from 6:33 a.m. to 7:36 22 a.m., do you know if he showed any kind of 23 signs of movement or life? 24 MS. : No. I don't. I arrived after. 25 And I have never heard of anything to the EFTA00127375 LIMITED OFFICIAL USE 1 contrary that he exhibited life. 2 MR. : Okay. And here is 3 another thing that was written in there, in the 4 BOP, and again, this is the BOP after-action 5 report. It says, "SHU has multiple cells 6 equipped with video recording capability. 7 Inmate Epstein was not housed in one of these 8 cells, and there appears to be no set guidance 9 on when to utilize these cells." So 10 specifically, I am assuming he is, they are 11 either talking about 10 South or possibly G- 12 tier. I'm not sure. I can't remember if G- 13 tier has cameras or not. But 10 South 14 certainly does. 15 MS. : Mm-hmm. 16 MR. : Do you believe that 17 Epstein should have been placed in one of those 18 cells that were, that had cameras in them? 19 MS. : I'm not going to say that. I'm 20 not going to say that he should have been 21 placed in a cell with a camera. He was an -. 22 He is an inmate, just like another inmate. So, 23 I can't, I can't say that, that he should have 24 definitely been placed in a cell. There 25 obviously was a reason that they felt that he EFTA00127376 LIMITED OFFICIAL USE 173 1 was safe, since he didn't say that he was going 2 to -. I don't -. Yeah. I can't say that he 3 should have definitely been placed in a cell 4 with a camera. 5 MR. : Okay. 6 MS. : Because those cells are for the 7 SAMs inmates. Those inmates that can't, you 8 know, their communication has to be monitored. 9 So, that is a different vetting process. 10 MR. : Okay. 11 MS. : Mm-hmm. 12 MR. : And do you -. These are 13 going to be the last, like, three or four 14 questions. Oh. What do you believe allowed 15 Epstein to be able to - if he took his own life 16 - what do you believe allowed Epstein to take 17 his own life? 18 MS. : Well, there were, I think his, 19 if that's what he wanted to do, without - 20 because the -. Now, we do know that staff 21 members have to make rounds. They're going 22 to, every, I don't know, 30 minutes, a regular 23 round. But he could have done it right before, 24 or right after the round. So, it doesn't mean 25 that he still - at the end - still wouldn't EFTA00127377 LIMITED OFFICIAL USE 174 1 have happened. So, I can't say for certain 2 that, we still would not have had the same 3 outcome. 4 So, I can't -. I know there was some 5 things that staff did not do that they were 6 supposed to do. Had they still made their 7 rounds, there is a possibility that a death 8 could have still have occurred, because there 9 are instances where staff make their rounds, 10 and inmates still are able to successfully 11 complete suicide, unfortunately. So, in this 12 instance, staff - we all, again, know - staff 13 did not do what they were, you know, supposed 14 to do by policy, but I can't say with certainty 15 that he still would not have been able to 16 successfully complete suicide. 17 MR. : So, it sounds like rounds 18 would have helped. What about having a 19 cellmate? Do you think that would have helped? 20 MS. : Yes. A cellmate would have 21 been able to alert a staff member, that is, if 22 they were alert and oriented themselves. 23 MR. : Yeah. I would think, 24 though, if a cellmate was in there, and they 25 saw someone hanging themselves, you know, EFTA00127378 LIMITED OFFICIAL USE 1- 1 obviously, there would be no requirement, I 2 guess, for them to do it, but that would 3 certainly indicate to that person that they 4 probably, there was an issue. Right? 5 MS. : Yeah. But when you say that, 6 when you say that, it depends on, see, if the 7 manner in which he committed suicide, he did it 8 because he was in there by himself. Yes. 9 MR. : Right. 10 MS. : But there is instances where 11 you have cellmates, if you are on, you could 12 have - an inmate could have tied a ligature 13 around his neck, if he was in his bed, and just 14 hung himself that way. So, again, there are 15 things that were not done on line with policy, 16 but I can't say for certain because we have, we 17 do have successful suicides, where staff do 18 follow procedure and follow policy. 19 MR. : But in this case, I 20 guess, you know, you know, correct me if I'm 21 wrong, but I would think that the two most 22 glaring things were the fact that he was 23 required to have a cellmate, and he didn't; and 24 that, also, staff were not conducting rounds as 25 they were required. Would you agree with that EFTA00127379 LIMITED OFFICIAL USE 176 1 assessment? 2 MS. : Yeah. We know that those 3 things did not happen. 4 MR. : And do you believe 5 anything else, you know, basically, if we are 6 looking at what all, you know, what could have 7 helped prevent this from happening in the 8 future? If we are looking at it as, you know, 9 like, well, what can we do better next time? 10 Aside from making sure, you know, cellmates 11 that are required to have cellmates have them, 12 and then, aside from making sure that staff are 13 actually conducting their rounds and counts, is 14 there anything else that should have been done? 15 MS. : Just -- 16 MR. : It sounds like you didn't 17 agree with putting him in a cell with a camera. 18 So, I'm just wondering if there is anything 19 else that -- 20 MS. : No. I'm not saying necessarily 21 I agree or disagree. I'm saying that there is 22 inmates that are in cells without cameras, and 23 they don't necessarily commit suicide. So, 24 what was the difference? Why did Epstein have 25 to be in a cell with a camera? So, I'm saying, EFTA00127380 LIMITED OFFICIAL USE 177 1 we don't -. That's not part of our policy, 2 that cameras have to be present. So, that is 3 not the -. That does -. That in and of itself 4 doesn't determine or make a difference whether 5 someone commits suicide or doesn't. 6 MR. : Sure. 7 MS. : Like, that's not a requirement. 8 MR. : So, I guess the - and I 9 probably got you off on track, on the camera 10 thing - I'm just saying, is there anything else 11 we are missing here, aside from, you know, what 12 we just discussed, as far as reasons that 13 allowed for Epstein to be able to take his 14 life? 15 MS. : No. 16 MR. : No. 17 MS. : I don't know. 18 MR. : Okay. What do you 19 believe the failures of the BOP - if you 20 believe there are any - that allowed for 21 Epstein to die? 22 MS. : I don't believe that the BOP is 23 responsible for him committing suicide. I 24 believe that, as you investigate, that there 25 are things that - may not have been with the EFTA00127381 LIMITED OFFICIAL USE 178 1 policy, but I don't believe that that 2 contributed to the suicide itself. Because, 3 like I said, I know we are looking at it after, 4 like, Monday morning quarterbacking, but there 5 are, there are some instances where there is a 6 successful suicide, where does not follow 7 protocol from top to bottom. And it happens, 8 unfortunately. And in this instance, they 9 didn't do everything that they were supposed to 10 do, or they didn't do a lot, but I don't 11 believe that it contributed to him committing 12 suicide. I don't. I don't really believe 13 that. 14 MR. : So, you don't believe - 15 and we didn't get into staff members sleeping - 16 but you don't believe that a staff member not 17 conducting rounds, a staff member sleeping on 18 the job, staff members not, you know, making 19 proper notifications and getting a new cellmate 20 into them, you don't believe that that is 21 contributed to him taking his own life? 22 MS. : I'm -- 23 MR. : The ability to do that? 24 MS. : hmm. Because when you are 25 saying staff members sleeping, yeah, if, even EFTA00127382 LIMITED OFFICIAL USE 179 1 if a staff member is awake, and that I'm saying 2 that because I'm aware of a successful suicide, 3 staff members can make their rounds every 30 4 minutes. And when they go by, unfortunately, 5 if someone actually is intent on committing 6 suicide, they can wait for you to make your 7 round, and they know that you don't have to 8 come back until another 30 minutes. 9 MR. : Sure. And I didn't say 10 that staff members -- 11 MS. (Indiscernible *02:47:32). 12 MR. : -- caused him to die. 13 what I said is, helped contribute, and allowed 14 for him -- 15 MS. : Yeah. 16 MR. : -- to take his life. So, 17 what I'm saying is, like, the job -- 18 MS. : Okay. 19 MR. : -- performance that 20 wasn't done, and that's why this investigation 21 pertains to security failure and job 22 performance failure, because it seems to me 23 that there was a lot of job performance failure 24 here, at the very least, in the sense that 25 people weren't doing their jobs. EFTA00127383 LIMITED OFFICIAL USE 180 1 MS. : Mm-hmm. 2 MR. : And that, that helped 3 cause, you know, and again, I think you 4 mentioned it, if a person wants to kill 5 themselves, they're probably going to be able 6 to find a way. But there is also things that, 7 when an inmate is in our custody, it is our job 8 to try to do everything we can to keep them 9 alive, and prevent that from happening. 10 MS. : Mm-hmm. 11 MR. : So, my question to you 12 is, you don't believe that, by though, you 13 know, them not doing those things, that that 14 helped contribute? 15 MS. : And I know this might sound 16 but you sound bewildered by my response, but I 17 believe that it contributed to some failures, 18 but I don't really believe that the failure 19 equals the contribution of the suicide. I 20 really don't believe that. 21 MR. : Okay. Yeah. I don't 22 know that I look at it as a contribution. I'm 23 just saying, the failures that allowed for him 24 to be able to take his own life. And so, 25 again, I'm not saying that they helped assist EFTA00127384 LIMITED OFFICIAL USE 181 1 him with taking his life, but by not doing -- 2 MS. : Mm-hmm. 3 MR. : -- their job, that, you 4 know, provided him ample opportunity to do so. 5 Would you agree with that? 6 MS. : Again, I'm going to - my thing 7 is going to be the same. 8 MR. : Okay. No. You're just 9 the first person I've talked to that said that. 10 MS. : Yeah. 11 MR. : Okay. That's totally 12 fine. Okay. Well, is there anything else that 13 I missed, or that you would like to add to 14 this? 15 MS. : Hmm-mm. No. 16 MR. : And , are you still 17 there? Is there any follow up questions that 18 you have, before we end this thing? 19 : No follow up questions. 20 MR. : All right. Great. Well, 21 you have my information. My cell phone. My 22 email. 23 MS. : Mm-hmm. 24 MR. : If there is anything you 25 need, please feel free to contact me. But EFTA00127385 LIMITED OFFICIAL USE 182 1 otherwise, I would very much greatly appreciate 2 if you get me that stuff we talked about, 3 specific with regard to the documents that you 4 5 MS. : Okay. 6 MR. : -- that you kept on file, 7 and I think you took - there was something else 8 that we discussed. What was the other thing? 9 Was it -? 10 MS. : You said it was about the bad 11 (Indiscernible *02:49:59). I made some notes 12 about the bad count. And then, about the court 13 document. 14 MR. : Perfect. Yeah. So, 15 there would be those specific things. But 16 again, anything -? I think you said you made 17 records of things that you produced, that would 18 be very much appreciated, as well. 19 MS. : Yeah. 20 MR. : It is 1:24 p.m. on 21 December 2nd, 2021. This is Senior Special 22 Agent and I am going to turn 23 off this recorder. 24 MS. : Okay. 25 (Whereupon, the above-entitled matter went EFTA00127386 LIMITED OFFICIAL USE 183 1 off the record and back on the record). 2 MR. : This is Senior Special 3 Agent It is currently 1:26 4 p.m., 12/02/2021. Prior to hanging up the 5 call, Associate Warden asked if I could 6 turn back on the recorder so she could make a 7 clarifying statement. So, Ms. , go ahead. 8 I'll just remind you, you are under oath, and 9 this is a voluntary interview. 10 MS. : I wanted to clarify whether I 11 feel that, some of the things helped, I guess 12 helped to, or contributed to, Epstein's ability 13 to commit suicide. While I understand that 14 this is something that no one wanted, there 15 were things that were not done, that were in 16 line with policy. That were required to be 17 done, and had those things been done, maybe we 18 would not be questioning the liability aspect. 19 But I just want to ensure that it's understood 20 that I have - I believe that staff should 21 follow policy, to ensure with certainty that no 22 inmate is able to hurt themselves, or that no 23 other inmate is able to hurt them. 24 So, with that knowledge, again, I really 25 hope that staff would have done everything EFTA00127387 LIMITED OFFICIAL USE 184 1 within their power to follow policy, so that 2 there would be no question as to what should or 3 should not have been done. And with 4 acknowledgement that there were not things done 5 that should have been done, as it relates to 6 following policy. 7 MR. : All right. Thank you 8 very much. Is there anything else you wanted 9 to add before I turn off the recorder and we 10 end this interview? 11 MS. : No. I think that's it. I just 12 wanted to add that as a sentiment, that I 13 understand that this is a serious matter, and 14 that it required care and attention, and that 15 it requires me to clarify what I believe 16 actually, you know, the staff did or did not 17 do. 18 MR. : Perfect. Thank you so 19 much. Again, if there is anything you need 20 from me, you have my email, and I will greatly 21 look forward to the information you can provide 22 following this interview. It is 1:28 p.m., 23 12/02/2021. This is Senior Special Agent 24 , and I am turning off the 25 recorder. EFTA00127388 LIMITED OFFICIAL USE 185 1 CERTIFICATE 2 I hereby certify that the foregoing pages 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 represent an accurate transcript of the electronic sound recording of the proceedings before the Department of Justice, Office of the Inspector General in the matter of: Interview of See,7s 45- -- Brianna Rose Burton, Transcriber EFTA00127389